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 grant of permission to the petitioner’s assessing authority, to re-assess the petitioner - The HC observed that, since, the assessing officer failed to make any specific order of assessment in terms of Section 29(6) of the Act till 30.09.2016, his powers to make the regular assessment stood exhausted. - The High court quashed the reassessment order dated 17.03.2021 and the permission granted for reassessment, deeming them nullities due to lack of jurisdiction and absence of a valid reason to believe that any part of the petitioner's turnover had escaped assessment.
Validity of grant of permission to the petitioner’s assessing authority, to re-assess the petitioner - The HC observed that, since, the assessing officer failed to make any specific order of assessment in terms of Section 29(6) of the Act till 30.09.2016, his powers to make the regular assessment stood exhausted. - The High court quashed the reassessment order dated 17.03.2021 and the permission granted for reassessment, deeming them nullities due to lack of jurisdiction and absence of a valid reason to believe that any part of the petitioner's turnover had escaped assessment.
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