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...
Period of limitation for commencement of arbitration. - What is the breaking point? - For the purpose of section 37 (1) anction and cause of arbitration should be construed as arbitration and course of arbitration. The cause of arbitration arises when the claimant becomes entitled to raise the question, that is, when the claimant acquires that right to require arbitration. - when the bank guarantee came to be encashed in the year 2016 and the requisite amount stood transferred to the Government account that was the end of the matter. This “Breaking Point” should be treated as the date at which the cause of action arose for the purpose of limitation. - SC
Period of limitation for commencement of arbitration. - What is the breaking point? - For the purpose of section 37 (1) anction and cause of arbitration should be construed as arbitration and course of arbitration. The cause of arbitration arises when the claimant becomes entitled to raise the question, that is, when the claimant acquires that right to require arbitration. - when the bank guarantee came to be encashed in the year 2016 and the requisite amount stood transferred to the Government account that was the end of the matter. This “Breaking Point” should be treated as the date at which the cause of action arose for the purpose of limitation. - SC
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