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...
Jurisdiction powers to issue Reopening notice in metro city - It was established that the notice under Section 148 of the Act was issued by an Income Tax Officer (ITO), whereas the jurisdiction allegedly lay with the Assistant Commissioner or Deputy Commissioner of Income Tax. The Tribunal referred to relevant instructions indicating the appropriate jurisdiction based on income levels. Relying on the decision of the Hon'ble Bombay High Court in a similar case, the Tribunal held that the notice issued by the ITO was without jurisdiction and thus rendered the assessment order invalid.
Jurisdiction powers to issue Reopening notice in metro city - It was established that the notice under Section 148 of the Act was issued by an Income Tax Officer (ITO), whereas the jurisdiction allegedly lay with the Assistant Commissioner or Deputy Commissioner of Income Tax. The Tribunal referred to relevant instructions indicating the appropriate jurisdiction based on income levels. Relying on the decision of the Hon'ble Bombay High Court in a similar case, the Tribunal held that the notice issued by the ITO was without jurisdiction and thus rendered the assessment order invalid.
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