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...
Application for settlement of cases - High Court has observed that, the assessment order for A.Ys. 2013-14 to 2019-20 could not have been passed as the application filed by the petitioner for settlement is considered to be pending and the Interim Board is required to exercise all the powers of the Settlement Commission with regard to pending application and accordingly, as per provision of section 245F(2) of the Act, the Interim Board is vested with the powers of the Settlement Commission and jurisdiction and Income Tax authority could not have proceeded further with the assessment proceedings in view of the pendency of the settlement application before the Interim Board.
Application for settlement of cases - High Court has observed that, the assessment order for A.Ys. 2013-14 to 2019-20 could not have been passed as the application filed by the petitioner for settlement is considered to be pending and the Interim Board is required to exercise all the powers of the Settlement Commission with regard to pending application and accordingly, as per provision of section 245F(2) of the Act, the Interim Board is vested with the powers of the Settlement Commission and jurisdiction and Income Tax authority could not have proceeded further with the assessment proceedings in view of the pendency of the settlement application before the Interim Board.
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