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 Initiation of proceedings u/s 153C - as argued satisfaction note of the searched person and satisfaction note of the petitioner (other than the searched person) are verbatim, proceedings are invalid - The High Court observed that, having noted the fact that the satisfaction note of the AO of the petitioner assessee has not been brought on record and moreover, the assessment note of the AO of the searched person indicates a prima facie case of inquiry against the petitioner, we do not find any substance in the argument of the learned Senior Counsel that the satisfaction note of the AO of the petitioner is to be discarded being a copy in verbatim of the satisfaction note of the AO of the searched person.
Validity of Initiation of proceedings u/s 153C - as argued satisfaction note of the searched person and satisfaction note of the petitioner (other than the searched person) are verbatim, proceedings are invalid - The High Court observed that, having noted the fact that the satisfaction note of the AO of the petitioner assessee has not been brought on record and moreover, the assessment note of the AO of the searched person indicates a prima facie case of inquiry against the petitioner, we do not find any substance in the argument of the learned Senior Counsel that the satisfaction note of the AO of the petitioner is to be discarded being a copy in verbatim of the satisfaction note of the AO of the searched person.
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