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...
Maintainability of revenue appeal against the order of CIT(A) granting relief to assessee - When NCLT has declared moratorium u/s 14 of IBC Code in the case of assessee, then there is a complete bar to initiate and continue proceedings against the assessee before any authority. Therefore, in view of the moratorium granted by NCLT, no proceedings against the assessee can continue. In view of the aforesaid facts, the appeal of Revenue deserves to be dismissed. - AT
Maintainability of revenue appeal against the order of CIT(A) granting relief to assessee - When NCLT has declared moratorium u/s 14 of IBC Code in the case of assessee, then there is a complete bar to initiate and continue proceedings against the assessee before any authority. Therefore, in view of the moratorium granted by NCLT, no proceedings against the assessee can continue. In view of the aforesaid facts, the appeal of Revenue deserves to be dismissed. - AT
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