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...
Validity of assessment passed u/s 153A pursuant to search and seizure - The High Court has observed and held that, the assessee’s assessment for the relevant year stood completed as on 06.06.2003 long before the search and consequent proceeding initiated u/s 153A and there is no question arising of the relevant assessment to abate under the second proviso to Section 153A. - Tribunal was perfectly within the statutory framework, in making a remand directing the AO to carry out re-assessment of the assessment year 2002-03, which stood completed as on the date of initiation of Section 153A proceedings, if some incriminating material seized during the search is available.
Validity of assessment passed u/s 153A pursuant to search and seizure - The High Court has observed and held that, the assessee’s assessment for the relevant year stood completed as on 06.06.2003 long before the search and consequent proceeding initiated u/s 153A and there is no question arising of the relevant assessment to abate under the second proviso to Section 153A. - Tribunal was perfectly within the statutory framework, in making a remand directing the AO to carry out re-assessment of the assessment year 2002-03, which stood completed as on the date of initiation of Section 153A proceedings, if some incriminating material seized during the search is available.
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