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...
Demand of differential service tax - From the SCN it is evident that all facts and figures were in the appellant’s records but they were belatedly scrutinized by auditors and investigating officers and the jurisdictional central excise officer has either not scrutinized the returns or having scrutinized, not issued a demand under section 73 - the demand for extended period of limitation and the penalties under section 78 set aside. - AT
Demand of differential service tax - From the SCN it is evident that all facts and figures were in the appellant’s records but they were belatedly scrutinized by auditors and investigating officers and the jurisdictional central excise officer has either not scrutinized the returns or having scrutinized, not issued a demand under section 73 - the demand for extended period of limitation and the penalties under section 78 set aside. - AT
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