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 143(3) r.w.s 144C - Period of limitation u/s 153 - Issuance of direction by the JCIT u/s 144A - The issuance of the direction and the communication of such direction by the Joint Commissioner to the assessing officer to aid in the completion of assessment is expected to be within the overall limits provided for completion of assessment under Section 153 and Explanation (1) thereto and nowhere it is contemplated that such reference would extend the limitation. - HC
Assessment u/s 143(3) r.w.s 144C - Period of limitation u/s 153 - Issuance of direction by the JCIT u/s 144A - The issuance of the direction and the communication of such direction by the Joint Commissioner to the assessing officer to aid in the completion of assessment is expected to be within the overall limits provided for completion of assessment under Section 153 and Explanation (1) thereto and nowhere it is contemplated that such reference would extend the limitation. - HC
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