Transfer pricing requires evidence for AMP transactions, functionally reliable comparables, and appropriate aggregation or Berry Ratio benchmarking me...
Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
Condonation of delay of 1433 days in filing appeal before the tribunal - Tribunal condoned the delay in revenue appeal - error of law or not - In view of the facts and circumstances and the law laid down by the Supreme Court and also the sufficient cause assigned in the applications for condonation of delay, the Revenue has assigned sufficient cause for the purpose of getting the delay condoned and the Tribunal was justified in allowing the applications - HC
Condonation of delay of 1433 days in filing appeal before the tribunal - Tribunal condoned the delay in revenue appeal - error of law or not - In view of the facts and circumstances and the law laid down by the Supreme Court and also the sufficient cause assigned in the applications for condonation of delay, the Revenue has assigned sufficient cause for the purpose of getting the delay condoned and the Tribunal was justified in allowing the applications - HC
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