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...
Condonation of Delay in filing the returns of income seeking refund - delay due to date of ruling of the AAR - genuine hardship - The delay in filing tax returns for AYs 2012-13 and 2013-14 by the petitioner was condoned under Section 119(2)(b) of the Income Tax Act, subject to payment of costs, due to genuine hardship. The assessing officer was directed to process the returns after compliance with the conditional order. - HC
Condonation of Delay in filing the returns of income seeking refund - delay due to date of ruling of the AAR - genuine hardship - The delay in filing tax returns for AYs 2012-13 and 2013-14 by the petitioner was condoned under Section 119(2)(b) of the Income Tax Act, subject to payment of costs, due to genuine hardship. The assessing officer was directed to process the returns after compliance with the conditional order. - HC
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