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...
Settlement application u/s 245C - Apportioning the undisclosed income in the hands of the petitioner and the Company - The High court examines the petitioner's disclosure and the basis for apportionment of income. It notes discrepancies and lack of clarity in the petitioner's submissions regarding the apportionment of unaccounted sales, expenditures, and income between the petitioner and the company. - The High court concurs with the Commission's finding that the petitioner did not disclose true and correct facts, violating the requirements of Section 245C(1).
Settlement application u/s 245C - Apportioning the undisclosed income in the hands of the petitioner and the Company - The High court examines the petitioner's disclosure and the basis for apportionment of income. It notes discrepancies and lack of clarity in the petitioner's submissions regarding the apportionment of unaccounted sales, expenditures, and income between the petitioner and the company. - The High court concurs with the Commission's finding that the petitioner did not disclose true and correct facts, violating the requirements of Section 245C(1).
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