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 assessment order passed u/s 144C - due to oversight/inadvertence Petitioner did not inform the AO within 30 days period prescribed under Sub-section (2) of Section 144C that it had filed objection by way of an email - The court disposes of the petition, setting aside the assessment order and remitting the matter to the DRP for consideration of the petitioner's objections. The Assessing Officer is directed to take further steps in accordance with the law after the DRP passes its order.
Validity of assessment order passed u/s 144C - due to oversight/inadvertence Petitioner did not inform the AO within 30 days period prescribed under Sub-section (2) of Section 144C that it had filed objection by way of an email - The court disposes of the petition, setting aside the assessment order and remitting the matter to the DRP for consideration of the petitioner's objections. The Assessing Officer is directed to take further steps in accordance with the law after the DRP passes its order.
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