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...
Effective date of a Circular issued by the CBEC - It is not possible to accept the contention advanced on behalf of the department that the circular dated 23.08.2007 is retrospective in nature. The said Circular supersedes all the past Circulars, clarifications and communications on all technical issues. - the Circular dated 23.08.2007 is oppressive in nature and it is a settled principal of law that an oppressive Circular should be given only prospective effect. - AT
Effective date of a Circular issued by the CBEC - It is not possible to accept the contention advanced on behalf of the department that the circular dated 23.08.2007 is retrospective in nature. The said Circular supersedes all the past Circulars, clarifications and communications on all technical issues. - the Circular dated 23.08.2007 is oppressive in nature and it is a settled principal of law that an oppressive Circular should be given only prospective effect. - AT
Note: It is a system-generated summary and is for quick reference only.