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 Revision u/s 263 - non mentioning computer generated DIN - Non-est order - Circular categorically mentions that subsequent to 01/10/2019, the computer generated DIN not only be allotted but be duly quoted in the body of the communication itself. - Neither the reasons nor the statement in the prescribed format is to be found in the order passed u/s 263 of the Act, spelling out the particular category of exception that prevented allotting the DIN on that day. It is yet another violation. - such an order shall be treated to have never been issued and, therefore, shall not take any affect. - AT
Validity of Revision u/s 263 - non mentioning computer generated DIN - Non-est order - Circular categorically mentions that subsequent to 01/10/2019, the computer generated DIN not only be allotted but be duly quoted in the body of the communication itself. - Neither the reasons nor the statement in the prescribed format is to be found in the order passed u/s 263 of the Act, spelling out the particular category of exception that prevented allotting the DIN on that day. It is yet another violation. - such an order shall be treated to have never been issued and, therefore, shall not take any affect. - AT
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