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...
Order u/s 119(2)(b) of the Act rejecting the application for waiver of time limit for filing of the return - claim in the refund on account of the tax deducted at source from the income of late father - The Court noted that the PCIT's rejection was contrary to established legal principles. Referring to precedents, the Court emphasized the need for a liberal interpretation of "genuine hardship" and justice-oriented approach in such matters. The High Court held that the petition succeeds and is accordingly allowed.
Order u/s 119(2)(b) of the Act rejecting the application for waiver of time limit for filing of the return - claim in the refund on account of the tax deducted at source from the income of late father - The Court noted that the PCIT's rejection was contrary to established legal principles. Referring to precedents, the Court emphasized the need for a liberal interpretation of "genuine hardship" and justice-oriented approach in such matters. The High Court held that the petition succeeds and is accordingly allowed.
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