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...
Violation under FERA - export proceeds were not realized - The case involved allegations of violations of the FERA Act, 1973 related to the failure to realize export proceeds. A1, A2, and A3 were implicated in export transactions, with evidence suggesting their involvement in facilitating exports and receiving funds. The court dismissed the revision cases, affirming the lower courts' findings of the petitioners' culpability under FERA provisions.
Violation under FERA - export proceeds were not realized - The case involved allegations of violations of the FERA Act, 1973 related to the failure to realize export proceeds. A1, A2, and A3 were implicated in export transactions, with evidence suggesting their involvement in facilitating exports and receiving funds. The court dismissed the revision cases, affirming the lower courts' findings of the petitioners' culpability under FERA provisions.
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