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...
Special audit u/s. 142(2A) - Challenge on the ground that order is subjective satisfaction, is non-speaking and has been mechanically passed - The objection of petitioner that there is no material to show that interest of Revenue was adversely affected hence the special audit was not helpful, has no legs to stand in view of element of public interest being pre-dominant in the object behind special audit. - HC
Special audit u/s. 142(2A) - Challenge on the ground that order is subjective satisfaction, is non-speaking and has been mechanically passed - The objection of petitioner that there is no material to show that interest of Revenue was adversely affected hence the special audit was not helpful, has no legs to stand in view of element of public interest being pre-dominant in the object behind special audit. - HC
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