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...
Revision u/s 263 - order passed on a deceased assessee - intimation about Death of assessee - There has been delay at the level of State Government in issuing necessary certificate. Fault cannot be placed on the Revenue or the assessee. - An appellate authority does not have the authority to extend the limitation. - Revision order quashed - AT
Revision u/s 263 - order passed on a deceased assessee - intimation about Death of assessee - There has been delay at the level of State Government in issuing necessary certificate. Fault cannot be placed on the Revenue or the assessee. - An appellate authority does not have the authority to extend the limitation. - Revision order quashed - AT
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