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...
Legality and validity of the provisional attachment of the bank account of the petitioner - It is not a case of complete evasion of tax by the petitioner - According to the Revenue, there is a short-payment of the tax due - It is mentioned that the quantum mentioned by the respondents is only a provisional figure even before issuance of show cause notice; not to speak of any adjudication order. In such a case, attaching bank account of the petitioner is not at all justified - HC
Legality and validity of the provisional attachment of the bank account of the petitioner - It is not a case of complete evasion of tax by the petitioner - According to the Revenue, there is a short-payment of the tax due - It is mentioned that the quantum mentioned by the respondents is only a provisional figure even before issuance of show cause notice; not to speak of any adjudication order. In such a case, attaching bank account of the petitioner is not at all justified - HC
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