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 assessment order u/s 143(3) r.w.s 263 - no intimation of DIN for the impugned order - The case of the assessee is that the communication, namely the assessment order is not only without mention of DIN in the body of the order, there is no material on the record mentioning the reason for non-issuance of DIN. Furthermore, the letter of intimation of DIN is also not within fifteen (15) working days of the issuance of the impugned assessment order - AT
Validity of assessment order u/s 143(3) r.w.s 263 - no intimation of DIN for the impugned order - The case of the assessee is that the communication, namely the assessment order is not only without mention of DIN in the body of the order, there is no material on the record mentioning the reason for non-issuance of DIN. Furthermore, the letter of intimation of DIN is also not within fifteen (15) working days of the issuance of the impugned assessment order - AT
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