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...
Assessment u/s 153C - inordinate delay in commencement of proceedings - The High court rejected the argument that the proceedings for AYs 2014-15 to 2016-17 were barred by limitation. It clarified that Section 153C, read with Section 153A, allows for assessment or reassessment for six years preceding the search year and for relevant assessment years beyond that, thus encompassing the years in question. - The court found that a consolidated Satisfaction Note suffices the requirements of Section 153C, provided it contains particulars of the incriminating material relevant to the block of AYs. It was determined that the respondents had collated substantial evidence warranting further scrutiny under the Act.
Assessment u/s 153C - inordinate delay in commencement of proceedings - The High court rejected the argument that the proceedings for AYs 2014-15 to 2016-17 were barred by limitation. It clarified that Section 153C, read with Section 153A, allows for assessment or reassessment for six years preceding the search year and for relevant assessment years beyond that, thus encompassing the years in question. - The court found that a consolidated Satisfaction Note suffices the requirements of Section 153C, provided it contains particulars of the incriminating material relevant to the block of AYs. It was determined that the respondents had collated substantial evidence warranting further scrutiny under the Act.
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