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...
Stay of recovery proceedings initiated under Section 226(3) - Political Party claiming exemption u/s 13A as appliable to Trusts, denied - The tribunal dismissed these allegations, highlighting that the Assessing Officer proceeded according to the due process of law. The claim of hardship was found to lack merit as the assessee had ample opportunities to address the demand, including a chance to pay 20% of the demand in October 2021, which was not taken. - While this issue's specific judicial reasoning is not provided in the Stay Application's context, the denial of exemption by the Assessing Officer underlines strict adherence to the statutory requirements of the Income-tax Act.
Stay of recovery proceedings initiated under Section 226(3) - Political Party claiming exemption u/s 13A as appliable to Trusts, denied - The tribunal dismissed these allegations, highlighting that the Assessing Officer proceeded according to the due process of law. The claim of hardship was found to lack merit as the assessee had ample opportunities to address the demand, including a chance to pay 20% of the demand in October 2021, which was not taken. - While this issue's specific judicial reasoning is not provided in the Stay Application's context, the denial of exemption by the Assessing Officer underlines strict adherence to the statutory requirements of the Income-tax Act.
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