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...
Exemption from Pre-deposit - The petitioner argued that their request for exemption from pre-deposit was wrongly rejected, and they challenged the jurisdiction of imposing liability. The court, after considering the submissions and relevant provisions of the Income Tax Act, directed the CIT (Appeals) to decide the appeal expeditiously without insisting on the pre-deposit. The court emphasized compliance with Notification and Instruction No. 1914 issued under Section 220 of the Income Tax Act. However, the judgment did not delve into the specifics of the jurisdictional challenge raised by the petitioner.
Exemption from Pre-deposit - The petitioner argued that their request for exemption from pre-deposit was wrongly rejected, and they challenged the jurisdiction of imposing liability. The court, after considering the submissions and relevant provisions of the Income Tax Act, directed the CIT (Appeals) to decide the appeal expeditiously without insisting on the pre-deposit. The court emphasized compliance with Notification and Instruction No. 1914 issued under Section 220 of the Income Tax Act. However, the judgment did not delve into the specifics of the jurisdictional challenge raised by the petitioner.
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