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...
Assessment after re-organization of Business - amalgamation or demerger or merger - To remove the difficulty of filling of return by successor it has been proposed to substitute sec 170A, to provide that notwithstanding anything contained in section 139, in a case of business re-organization, where prior to the date of order of the tribunal or the High Court or Adjudicating Authority as defined in clause (1) of section 5 of the Insolvency and Bankruptcy Code, 2016, Successor shall furnish modified return within 6 months & AO will in case of assessment or reassessment consider the modified return as valid return for that purpose.-
Assessment after re-organization of Business - amalgamation or demerger or merger - To remove the difficulty of filling of return by successor it has been proposed to substitute sec 170A, to provide that notwithstanding anything contained in section 139, in a case of business re-organization, where prior to the date of order of the tribunal or the High Court or Adjudicating Authority as defined in clause (1) of section 5 of the Insolvency and Bankruptcy Code, 2016, Successor shall furnish modified return within 6 months & AO will in case of assessment or reassessment consider the modified return as valid return for that purpose.-
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