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 reopening notice - Absence of the manual/digital signature of the A.O in the copy of the Reopening notice - Elaborating on the term "signed", it was observed that that same was to be construed as giving one's name to signify assent or adhesion to by signing one's name; to attest by signing or when a person is unable to write his name then affixation of "mark" by such person. - The Tribunal highlighted significant procedural lapses, notably the absence of the Assessing Officer's signature on the notice under section 148, leading to the quashing of the assessment order. The Tribunal's decision underscores the importance of adhering to procedural requirements, emphasizing that such lapses can invalidate otherwise substantive assessments.
Validity of reopening notice - Absence of the manual/digital signature of the A.O in the copy of the Reopening notice - Elaborating on the term "signed", it was observed that that same was to be construed as giving one's name to signify assent or adhesion to by signing one's name; to attest by signing or when a person is unable to write his name then affixation of "mark" by such person. - The Tribunal highlighted significant procedural lapses, notably the absence of the Assessing Officer's signature on the notice under section 148, leading to the quashing of the assessment order. The Tribunal's decision underscores the importance of adhering to procedural requirements, emphasizing that such lapses can invalidate otherwise substantive assessments.
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