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...
Presence of Advocate during Enquiry/interrogation as a matter of right - in the earlier judgements of the High Court’s, the presence of advocate was allowed on the basis of apprehensions that there may be some coercive attempt may be made against the petitioner. Since in the present case there is no such apprehension, the presence of advocate cannot be allowed as a matter of right during investigation. - HC
Presence of Advocate during Enquiry/interrogation as a matter of right - in the earlier judgements of the High Court’s, the presence of advocate was allowed on the basis of apprehensions that there may be some coercive attempt may be made against the petitioner. Since in the present case there is no such apprehension, the presence of advocate cannot be allowed as a matter of right during investigation. - HC
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