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...
Reopening of assessment u/s 147 - filing of objections to the issuance of notice u/s 148A - The day on which the request is made for adjournment either needs approval or rejection, however, once having kept silence and many days to have passed, it cannot suddenly choose to insist on answering within 24 hours as the other-side would also not be wrong in presuming that such a request is already acceded to - HC
Reopening of assessment u/s 147 - filing of objections to the issuance of notice u/s 148A - The day on which the request is made for adjournment either needs approval or rejection, however, once having kept silence and many days to have passed, it cannot suddenly choose to insist on answering within 24 hours as the other-side would also not be wrong in presuming that such a request is already acceded to - HC
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