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 - clandestine and unaccounted sales - The High Court reviewed a petition challenging the rejection of objections to a notice for reassessment under the Income Tax Act. The petitioner argued that the reassessment was based on a change of opinion rather than a mistake. The court examined the assessment procedure and found that the reasons for reopening the assessment did not indicate the discovery of new material but rather a potential change of opinion. - Consequently, the court quashed the impugned order and notice, ruling in favor of the petitioner.
Validity of reopening of assessment - clandestine and unaccounted sales - The High Court reviewed a petition challenging the rejection of objections to a notice for reassessment under the Income Tax Act. The petitioner argued that the reassessment was based on a change of opinion rather than a mistake. The court examined the assessment procedure and found that the reasons for reopening the assessment did not indicate the discovery of new material but rather a potential change of opinion. - Consequently, the court quashed the impugned order and notice, ruling in favor of the petitioner.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4809 
Join Channel 
