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...
Jurisdiction of CIT (A) while passing an order in appeal u/s 250 - Validity of assessment framed without issue of notice u/s. 143(2) - whether CIT (A) has exceeded his jurisdiction by directing the Ld. AO to proceed in terms of section 150 of the Income Tax Act, 1961 and reframe assessment order as per law and after complying with the prescribed procedure? - The ITAT held that, the CIT(A) has set aside the assessment the power which he does not have, therefore, the order of the CIT(A) to this extent is bad in law as the CIT(A) has exceeded his jurisdiction.
Jurisdiction of CIT (A) while passing an order in appeal u/s 250 - Validity of assessment framed without issue of notice u/s. 143(2) - whether CIT (A) has exceeded his jurisdiction by directing the Ld. AO to proceed in terms of section 150 of the Income Tax Act, 1961 and reframe assessment order as per law and after complying with the prescribed procedure? - The ITAT held that, the CIT(A) has set aside the assessment the power which he does not have, therefore, the order of the CIT(A) to this extent is bad in law as the CIT(A) has exceeded his jurisdiction.
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