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 - proceedings against the dissolved entity - notice in the name of petitioner LLP stood dissolved - the impugned notices and order are set aside. - Liberty is, however, given to AO to issue to Ms Ragini Mohan, who is the Legal Representative (LR) of the deceased managing partner fresh notice u/s 148A(b) of the Act. - HC
Validity of reopening of assessment - proceedings against the dissolved entity - notice in the name of petitioner LLP stood dissolved - the impugned notices and order are set aside. - Liberty is, however, given to AO to issue to Ms Ragini Mohan, who is the Legal Representative (LR) of the deceased managing partner fresh notice u/s 148A(b) of the Act. - HC
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