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...
Constitutional validity of amendment in the Area Based exemption - Denial of benefit of exemption - exclusion of a particular khasra in the Excise Notification - It is apparent from the prayer clause of the writ petition that the petitioner says that exclusion of a particular khasra in the Excise Notification No. 50/2003-CE dated 10.06.2003 is merely procedural, still, it touches upon the policy of the State Government and, hence, should not be rightly interfered by the Court exercising review jurisdiction under Article 226 of the Constitution of India. - HC
Constitutional validity of amendment in the Area Based exemption - Denial of benefit of exemption - exclusion of a particular khasra in the Excise Notification - It is apparent from the prayer clause of the writ petition that the petitioner says that exclusion of a particular khasra in the Excise Notification No. 50/2003-CE dated 10.06.2003 is merely procedural, still, it touches upon the policy of the State Government and, hence, should not be rightly interfered by the Court exercising review jurisdiction under Article 226 of the Constitution of India. - HC
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