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...
Validity of revival notices - original show cause notices were issued to the petitioners between the years 2007 and 2012 - revival of these proceedings after a gross inordinate and unexplained delay is clearly unjustified. Furthermore, non-intimation of the decision to transfer the original show cause notices to the Call Book to the petitioners herein, has resulted into grave prejudice being caused to them because on account of the delay in revival of the notices, the opportunity of contesting the assessment proceedings has been severely impaired. - HC
Validity of revival notices - original show cause notices were issued to the petitioners between the years 2007 and 2012 - revival of these proceedings after a gross inordinate and unexplained delay is clearly unjustified. Furthermore, non-intimation of the decision to transfer the original show cause notices to the Call Book to the petitioners herein, has resulted into grave prejudice being caused to them because on account of the delay in revival of the notices, the opportunity of contesting the assessment proceedings has been severely impaired. - HC
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