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...
Ex parte orders passed - non-compliance by the assessee to various notices issued to it by the lower authorities - Looking to the non-cooperative attitude of the assessee right from the very beginning i.e. the assessment proceedings, we are not inclined to show any liberty to such an assessee who does not appear to be interested to fight for her own cause. - AT
Ex parte orders passed - non-compliance by the assessee to various notices issued to it by the lower authorities - Looking to the non-cooperative attitude of the assessee right from the very beginning i.e. the assessment proceedings, we are not inclined to show any liberty to such an assessee who does not appear to be interested to fight for her own cause. - AT
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