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...
Reopening of assessment u/s 147 - the firm to which the notice has been sent is no longer in existence, as it has been succeeded by a company - The mere filing of letter dated 07.12.2021 will not exonerate the petitioners from not responding to the earlier and subsequent notices issued and it is of the considered view that no infirmity is made out warranting interference in the impugned orders under Article 226 of the Constitution of India. - HC
Reopening of assessment u/s 147 - the firm to which the notice has been sent is no longer in existence, as it has been succeeded by a company - The mere filing of letter dated 07.12.2021 will not exonerate the petitioners from not responding to the earlier and subsequent notices issued and it is of the considered view that no infirmity is made out warranting interference in the impugned orders under Article 226 of the Constitution of India. - HC
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