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 u/s 153A - Time limit for completion of assessments and reassessments - The contention that passing fresh assessment order pursuant to the Tribunal’s order dated 07.01.2016, is barred under the provisions to Section 153(3) and 153(4) of the Act, is merited. - We also express our displeasure in the manner the present matter has been dealt with by the concerned officer. - HC
Assessment u/s 153A - Time limit for completion of assessments and reassessments - The contention that passing fresh assessment order pursuant to the Tribunal’s order dated 07.01.2016, is barred under the provisions to Section 153(3) and 153(4) of the Act, is merited. - We also express our displeasure in the manner the present matter has been dealt with by the concerned officer. - HC
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