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...
Right to Information (RTI) relating to assessee relating to income tax - supremacy of RTI or IT Act - as contented any information relating to any assessee relating to income tax can be sought for only in the manner prescribed u/s 138 of the Income Tax Act and not under the Right to Information Act, 2005 - Section 11 of the RTI Act prescribes that any information related to a third party can only be divulged after giving notice to the said third party. In view of the above, the CIC ought to have followed the procedure specified under Section 11 of the RTI Act before ordering for grant of information as sought for by the Respondent herein. - CIC does not have the jurisdiction to direct furnishing of information, provided for in Section 138 of the IT Act. - HC
Right to Information (RTI) relating to assessee relating to income tax - supremacy of RTI or IT Act - as contented any information relating to any assessee relating to income tax can be sought for only in the manner prescribed u/s 138 of the Income Tax Act and not under the Right to Information Act, 2005 - Section 11 of the RTI Act prescribes that any information related to a third party can only be divulged after giving notice to the said third party. In view of the above, the CIC ought to have followed the procedure specified under Section 11 of the RTI Act before ordering for grant of information as sought for by the Respondent herein. - CIC does not have the jurisdiction to direct furnishing of information, provided for in Section 138 of the IT Act. - HC
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