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...
Cancellation of registration granted u/s 12AB - Assessment of trust - The ITAT held that the PCIT's order to cancel the registration from the financial year 2020-21 and subsequent years under section 12AB(4)(ii) was beyond his jurisdiction, particularly for the assessment year 2021-22, as the provision was not applicable retrospectively. - The Tribunal clarified that the law applicable to an assessment year should be the law in force for that year unless specified otherwise.
Cancellation of registration granted u/s 12AB - Assessment of trust - The ITAT held that the PCIT's order to cancel the registration from the financial year 2020-21 and subsequent years under section 12AB(4)(ii) was beyond his jurisdiction, particularly for the assessment year 2021-22, as the provision was not applicable retrospectively. - The Tribunal clarified that the law applicable to an assessment year should be the law in force for that year unless specified otherwise.
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