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...
Recovery of demand - initiation of Garnishee proceedings - The assessment order and the demand does not remain merely a piece of paper, unless an assessee gets relief by a higher authority against the assessment order and demand arising from it, it is the statutory duty of the officer to see that the demand arising out of an adjudication order is being realised. Further, adjudication order in question out of which the demand in question arises is an appealable order and till date petitioner has not availed any remedy under the statute by way of filing appeal against the same. - Petition dismissed - HC
Recovery of demand - initiation of Garnishee proceedings - The assessment order and the demand does not remain merely a piece of paper, unless an assessee gets relief by a higher authority against the assessment order and demand arising from it, it is the statutory duty of the officer to see that the demand arising out of an adjudication order is being realised. Further, adjudication order in question out of which the demand in question arises is an appealable order and till date petitioner has not availed any remedy under the statute by way of filing appeal against the same. - Petition dismissed - HC
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