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...
Reopening of earlier orders of ITAT for making additions towards delayed payment of employee’s contribution to ESI and PF - if the Apex Court intended its judgment to be applied prospectively, it would have provided a specific rider - as no such rider is found in the Checkmate Services Pvt. Ltd. vs. Commissioner of Income Tax-I case, it is concluded that the judgment has retrospective application - ITAT recall the respective orders - Appeals filed by the revenue allowed - AT
Reopening of earlier orders of ITAT for making additions towards delayed payment of employee’s contribution to ESI and PF - if the Apex Court intended its judgment to be applied prospectively, it would have provided a specific rider - as no such rider is found in the Checkmate Services Pvt. Ltd. vs. Commissioner of Income Tax-I case, it is concluded that the judgment has retrospective application - ITAT recall the respective orders - Appeals filed by the revenue allowed - AT
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