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...
Period of limitation - deeming a person to be an assessee-in-default - Non deduction of TDS - The Tribunal quashed the order dated 31.10.2019 issued u/s201(1) of the Income Tax Act, deeming it to be barred by limitation. The Tribunal followed its earlier decision, which held that amendments made to the statute with effect from 01/10/2014 are prospective, and concluded that the order should have been framed on or before 31.03.2015. As the order was framed on 31.10.2019, it was found to be time-barred. - AT
Period of limitation - deeming a person to be an assessee-in-default - Non deduction of TDS - The Tribunal quashed the order dated 31.10.2019 issued u/s201(1) of the Income Tax Act, deeming it to be barred by limitation. The Tribunal followed its earlier decision, which held that amendments made to the statute with effect from 01/10/2014 are prospective, and concluded that the order should have been framed on or before 31.03.2015. As the order was framed on 31.10.2019, it was found to be time-barred. - AT
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