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...
Reopening of assessment u/s 147 - notice u/s 148A(b) - the intent behind issuing the notice u/s 148A(b) is to inform the assessee of the allegations against him/her with sufficient particulars so that he/she can put forward his/her defence - AO has been negligent in incorporating the incorrect information and in not admitting the fact that he had committed a mistake while issuing a notice under Section 148A(b) of the Act even at the time of passing the order u/s 148A(d) of the Act. - HC
Reopening of assessment u/s 147 - notice u/s 148A(b) - the intent behind issuing the notice u/s 148A(b) is to inform the assessee of the allegations against him/her with sufficient particulars so that he/she can put forward his/her defence - AO has been negligent in incorporating the incorrect information and in not admitting the fact that he had committed a mistake while issuing a notice under Section 148A(b) of the Act even at the time of passing the order u/s 148A(d) of the Act. - HC
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4800
Join Channel
TaxTMI 
