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...
Reopening of assessment u/s 147 consequent to revision proceedings u/s 263 pending - notice u/s 148 issued during the pendency of the assessment proceedings following the directions given by the PCIT - The High Court held that such a notice could not be issued as long as assessment proceedings were ongoing, as income cannot be considered to have escaped assessment until these proceedings are completed. Additionally, the court found the sanction granted under Section 151 of the Act to be invalid based on a previous ruling. Consequently, the petition was disposed of in favor of the petitioner.
Reopening of assessment u/s 147 consequent to revision proceedings u/s 263 pending - notice u/s 148 issued during the pendency of the assessment proceedings following the directions given by the PCIT - The High Court held that such a notice could not be issued as long as assessment proceedings were ongoing, as income cannot be considered to have escaped assessment until these proceedings are completed. Additionally, the court found the sanction granted under Section 151 of the Act to be invalid based on a previous ruling. Consequently, the petition was disposed of in favor of the petitioner.
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