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...
Scope of Rectification u/s 254 - Power of ITAT - valuation of a bundle of sports rights purchased by the petitioner - Despite detailed expert opinions and submissions by the petitioner, the Tribunal opted for a blanket remand to the TPO for fresh valuation, without addressing key issues raised by the petitioner. - The High Court referenced previous judgments, emphasizing the duty of the Tribunal to consider all factual and legal issues before remanding cases. - The Court highlighted the mistake apparent from the record, emphasizing that the Tribunal's failure to address fundamental submissions made by the petitioner warranted rectification of the order. - Matter restored back before the Tribunal.
Scope of Rectification u/s 254 - Power of ITAT - valuation of a bundle of sports rights purchased by the petitioner - Despite detailed expert opinions and submissions by the petitioner, the Tribunal opted for a blanket remand to the TPO for fresh valuation, without addressing key issues raised by the petitioner. - The High Court referenced previous judgments, emphasizing the duty of the Tribunal to consider all factual and legal issues before remanding cases. - The Court highlighted the mistake apparent from the record, emphasizing that the Tribunal's failure to address fundamental submissions made by the petitioner warranted rectification of the order. - Matter restored back before the Tribunal.
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