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...
Validity of assessment order passed u/s 153A r.w.s. 143(3) - Extension of period of limitation - reference made by the revenue to Swiss authorities - Since the reference is not a valid reference, the claim of the revenue that period of limitation is extended by one year under section 153B based on the reference is not tenable - AT
Validity of assessment order passed u/s 153A r.w.s. 143(3) - Extension of period of limitation - reference made by the revenue to Swiss authorities - Since the reference is not a valid reference, the claim of the revenue that period of limitation is extended by one year under section 153B based on the reference is not tenable - AT
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