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...
Attachment of Overdraft Bank Accounts - garnishee proceedings - the appellate authority cannot entertain the appeal without hearing and without the appellant complying with the mandatory pre-deposit condition as contemplated under the provisions of the W.B.VAT Act. That apart, no useful purpose would be served by attaching an overdraft account by way of garnishee proceedings.Therefore, in our view, such attachment needs to be lifted however, subject to the condition that the appellant pays the mandatory pre-deposit payable in terms of the relevant provisions of the W.B.VAT Act. - HC
Attachment of Overdraft Bank Accounts - garnishee proceedings - the appellate authority cannot entertain the appeal without hearing and without the appellant complying with the mandatory pre-deposit condition as contemplated under the provisions of the W.B.VAT Act. That apart, no useful purpose would be served by attaching an overdraft account by way of garnishee proceedings.Therefore, in our view, such attachment needs to be lifted however, subject to the condition that the appellant pays the mandatory pre-deposit payable in terms of the relevant provisions of the W.B.VAT Act. - HC
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