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...
Benami transaction - The petitioner argues that the transactions in question occurred before the amendment of the Act in 2016, making the notice and order invalid. They rely on Supreme Court judgments and decisions of appellate tribunals and other High Courts to support their position. - The High Court, however, finds that the show cause notice and provisional attachment order are provisional in nature and subject to judicial review by the adjudicating authority. It declines to entertain the petitions at this stage, emphasizing the availability of statutory alternative remedies.
Benami transaction - The petitioner argues that the transactions in question occurred before the amendment of the Act in 2016, making the notice and order invalid. They rely on Supreme Court judgments and decisions of appellate tribunals and other High Courts to support their position. - The High Court, however, finds that the show cause notice and provisional attachment order are provisional in nature and subject to judicial review by the adjudicating authority. It declines to entertain the petitions at this stage, emphasizing the availability of statutory alternative remedies.
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