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...
Levy of Entry tax - tractor trolly - ‘motor vehicle’ - the trolly cannot exist as a motor vehicle independent of the ‘tractor’ to which it is supposed to be attached. - since the tractor itself is excluded from the definition of ‘motor vehicle’ under Section 2(h) of the OET Act, the question of bringing ‘trolly’ as a stand-alone vehicle within the purview of that definition does not arise. - HC
Levy of Entry tax - tractor trolly - ‘motor vehicle’ - the trolly cannot exist as a motor vehicle independent of the ‘tractor’ to which it is supposed to be attached. - since the tractor itself is excluded from the definition of ‘motor vehicle’ under Section 2(h) of the OET Act, the question of bringing ‘trolly’ as a stand-alone vehicle within the purview of that definition does not arise. - HC
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