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...
Suo-moto re-credit - duty paid twice - The appellant being law abiding assessee even though suo-moto credit was available to them, they had reversed the same on pointing out by the audit officers. Thereafter, the department could have regularized by allowing the re-credit but instead the appellant were issued the show cause notice for demand of re-credit made by the appellant suo-moto despite the fact that they had already reversed the same - the show cause notice itself ab initio, void and illegal. - AT
Suo-moto re-credit - duty paid twice - The appellant being law abiding assessee even though suo-moto credit was available to them, they had reversed the same on pointing out by the audit officers. Thereafter, the department could have regularized by allowing the re-credit but instead the appellant were issued the show cause notice for demand of re-credit made by the appellant suo-moto despite the fact that they had already reversed the same - the show cause notice itself ab initio, void and illegal. - AT
Note: It is a system-generated summary and is for quick reference only.