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...
Bogus share transactions - Reliance on the statement of broker/entry operator - the denial of opportunity for cross-examination by the Assessing Officer was a failure of the principles of natural justice and thus the evidence used against the assessee was discarded. The Tribunal also recognized the assessee's documentation supporting the transactions, including ledger accounts, purchase and sale bills, and bank statements. - AT
Bogus share transactions - Reliance on the statement of broker/entry operator - the denial of opportunity for cross-examination by the Assessing Officer was a failure of the principles of natural justice and thus the evidence used against the assessee was discarded. The Tribunal also recognized the assessee's documentation supporting the transactions, including ledger accounts, purchase and sale bills, and bank statements. - AT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4798
Join Channel
TaxTMI 
