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...
Revision u/s 263 - addition u/s. 68 r.w.s. 115BBE - Assessee has submitted before the AO that the repayment of unsecured loan was made from sell proceeds - the Tribunal was right in holding that it was not a case where there was lack of inquiry and therefore there was no ground on which revisionary powers under Section 263 could have been invoked - HC
Revision u/s 263 - addition u/s. 68 r.w.s. 115BBE - Assessee has submitted before the AO that the repayment of unsecured loan was made from sell proceeds - the Tribunal was right in holding that it was not a case where there was lack of inquiry and therefore there was no ground on which revisionary powers under Section 263 could have been invoked - HC
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