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 reopening notice issued u/s 148A - not signed either physically or digitally - minimum period of seven days prescribed u/s 148A(b) not provided - - The High court, in its analysis, referred to precedents and held that the notices were indeed invalid due to lack of signature and non-compliance with prescribed time periods. Consequently, the court quashed the impugned notices and orders while reserving liberty for the respondents to initiate proceedings in accordance with the law.
Validity of reopening notice issued u/s 148A - not signed either physically or digitally - minimum period of seven days prescribed u/s 148A(b) not provided - - The High court, in its analysis, referred to precedents and held that the notices were indeed invalid due to lack of signature and non-compliance with prescribed time periods. Consequently, the court quashed the impugned notices and orders while reserving liberty for the respondents to initiate proceedings in accordance with the law.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4798
Join Channel
TaxTMI 
