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...
Order u/s 148A(b) as passed against the petitioner in respect of the old PAN card - The Court noted that both the old and the new PAN cards of the petitioner were active, and since the old PAN card was used for transactions in the assessment year 2018-19, and the proceedings related to it were pending, the request for deletion of the old PAN could not be considered. The petitioner had transitioned from the old PAN card to a new one but faced issues due to an assessment order pertaining to the old PAN for unexplained money u/s 69A of the Income Tax Act. The Court directed that if the petitioner files an appeal using the old PAN, it should be processed in accordance with the law.
Order u/s 148A(b) as passed against the petitioner in respect of the old PAN card - The Court noted that both the old and the new PAN cards of the petitioner were active, and since the old PAN card was used for transactions in the assessment year 2018-19, and the proceedings related to it were pending, the request for deletion of the old PAN could not be considered. The petitioner had transitioned from the old PAN card to a new one but faced issues due to an assessment order pertaining to the old PAN for unexplained money u/s 69A of the Income Tax Act. The Court directed that if the petitioner files an appeal using the old PAN, it should be processed in accordance with the law.
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