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 draft assessment order u/s 144C(1) - difference in numbers in closing and opening stock of Lingerie - The show cause notice lacked specific quantification of proposed additions to income - The High court directed that the draft assessment order be treated as a show cause notice, allowing the petitioner to submit a reply within three weeks. The assessing officer was instructed to provide a reasonable opportunity, including a personal hearing through video conferencing, before issuing a fresh draft assessment order.
Validity of draft assessment order u/s 144C(1) - difference in numbers in closing and opening stock of Lingerie - The show cause notice lacked specific quantification of proposed additions to income - The High court directed that the draft assessment order be treated as a show cause notice, allowing the petitioner to submit a reply within three weeks. The assessing officer was instructed to provide a reasonable opportunity, including a personal hearing through video conferencing, before issuing a fresh draft assessment order.
Note: It is a system-generated summary and is for quick reference only.