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...
Exemption u/s 11 and 12 - assessee failed to file the Audit Report in Form 10B along with the Return of Income - None of the authorities had any occasion to verify Audit Report in Form 10B belatedly filed by the assessee. Further there is no regular assessment order passed u/s. 143(3) - AO directed to verify the Audit Report in Form No. 10B and then allow the claim of exemption u/s. 11 of the Act, in accordance with law by giving adequate opportunity to the assessee. - AT
Exemption u/s 11 and 12 - assessee failed to file the Audit Report in Form 10B along with the Return of Income - None of the authorities had any occasion to verify Audit Report in Form 10B belatedly filed by the assessee. Further there is no regular assessment order passed u/s. 143(3) - AO directed to verify the Audit Report in Form No. 10B and then allow the claim of exemption u/s. 11 of the Act, in accordance with law by giving adequate opportunity to the assessee. - AT
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