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...
Reopening of assessment - as alleged Petitioner was a beneficiary of accommodation entries - Notices under Section 148A(b) were issued, alleging escaped income, followed by a subsequent notice clarifying errors. - Petitioner's response, supported by evidence, was rejected for failure to submit documents not initially requested. - The High Court quashed the rejection order and remanded the matter for reconsideration. The assessing officer was directed to provide a reasoned decision and justify the rejection of petitioner's evidence.
Reopening of assessment - as alleged Petitioner was a beneficiary of accommodation entries - Notices under Section 148A(b) were issued, alleging escaped income, followed by a subsequent notice clarifying errors. - Petitioner's response, supported by evidence, was rejected for failure to submit documents not initially requested. - The High Court quashed the rejection order and remanded the matter for reconsideration. The assessing officer was directed to provide a reasoned decision and justify the rejection of petitioner's evidence.
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