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 of assessment u/s 147 - Reason to believe - The court scrutinized the purported tangible material for reopening, which consisted of audit objections received after the original assessment. However, it noted that the objections had been duly explained by the petitioner during the original assessment proceedings, and the assessing officer had found the explanations satisfactory. Therefore, the court concluded that there was no fresh tangible material justifying the reopening of the assessment.
Validity of reopening of assessment u/s 147 - Reason to believe - The court scrutinized the purported tangible material for reopening, which consisted of audit objections received after the original assessment. However, it noted that the objections had been duly explained by the petitioner during the original assessment proceedings, and the assessing officer had found the explanations satisfactory. Therefore, the court concluded that there was no fresh tangible material justifying the reopening of the assessment.
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