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...
Default u/s 201(1) - Short deduction of TDS - Non-residents - transaction of sale of property - The assessee cannot be treated as assessee in default u/s 201(1) of the Act, in the event, where the seller/payee/deductee a none resident has filed return of income and has offered the long term capital gain accrued to him from transfer of sale of property to the assessee for taxation then the assessee can not be held or treated as assessee in default. - AT
Default u/s 201(1) - Short deduction of TDS - Non-residents - transaction of sale of property - The assessee cannot be treated as assessee in default u/s 201(1) of the Act, in the event, where the seller/payee/deductee a none resident has filed return of income and has offered the long term capital gain accrued to him from transfer of sale of property to the assessee for taxation then the assessee can not be held or treated as assessee in default. - AT
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