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...
Validity of Reopening of assessment u/s 147 - notice issued to a non-existing company - it is very clear that the assessee did not inform the AO as required under the law about striking off name of the company from the RoC and hence, we are of the considered view that case law referred to by the assessee has no application to facts of the present case - AT
Validity of Reopening of assessment u/s 147 - notice issued to a non-existing company - it is very clear that the assessee did not inform the AO as required under the law about striking off name of the company from the RoC and hence, we are of the considered view that case law referred to by the assessee has no application to facts of the present case - AT
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