Pure-agent exclusion fails where hotel booking facilitators receive third-party services themselves, making entire customer consideration taxable as r...
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...
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Reopening of assessment u/s 147 - Service of the Notice u/s 148 - Over enthusiastically and by way of abundant caution, the notice u/s148 has been sent yet again on 31.07.2019 and this has been received by one 'A.Lakshmi' on 31.07.2019. According to petitioner, there is nobody by that name in that address. However, this is really irrelevant, since service of notice u/s 148 on the petitioner is already been complete even at first instance. - HC
Reopening of assessment u/s 147 - Service of the Notice u/s 148 - Over enthusiastically and by way of abundant caution, the notice u/s148 has been sent yet again on 31.07.2019 and this has been received by one 'A.Lakshmi' on 31.07.2019. According to petitioner, there is nobody by that name in that address. However, this is really irrelevant, since service of notice u/s 148 on the petitioner is already been complete even at first instance. - HC
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