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...
Bunching of show cause notices - Scope of section 73 - SCN is to be issued for each financial separately or bunching for 5 years is valid - Applicability of period of limitation - Direction issued for disposal of the representation of the petitioner to split up the show cause notices for each year separately. - HC
Bunching of show cause notices - Scope of section 73 - SCN is to be issued for each financial separately or bunching for 5 years is valid - Applicability of period of limitation - Direction issued for disposal of the representation of the petitioner to split up the show cause notices for each year separately. - HC
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