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 assessment order - As a matter of fact, the law casts an obligation on the revenue to inform the assessee in no uncertain words as to the charge against him i.e., as to whether it is a case for concealment, or omission or failure to disclose material particulars or a sum of one or more infractions. - There are too many infractions committed by the respondent/revenue in the instant matter - HC
Validity of assessment order - As a matter of fact, the law casts an obligation on the revenue to inform the assessee in no uncertain words as to the charge against him i.e., as to whether it is a case for concealment, or omission or failure to disclose material particulars or a sum of one or more infractions. - There are too many infractions committed by the respondent/revenue in the instant matter - HC
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