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 Charge memo issued to CIT(A) - The case involved a challenge to an order issued by the Central Administrative Tribunal, which had quashed a charge memo against the respondent, a former Commissioner of Income Tax (Appeals). The petitioners alleged that the respondent had wrongly decided five appeals during his tenure, prompting the issuance of the charge memo in 2014. However, the High Court found that the delay of over ten years in issuing the charge memo was unjustified and could prejudice the respondent's defense. Despite arguments regarding the applicability of previous court decisions and the nature of the respondent's duties, the Court upheld the Tribunal's decision and dismissed the writ petition.
Validity of Charge memo issued to CIT(A) - The case involved a challenge to an order issued by the Central Administrative Tribunal, which had quashed a charge memo against the respondent, a former Commissioner of Income Tax (Appeals). The petitioners alleged that the respondent had wrongly decided five appeals during his tenure, prompting the issuance of the charge memo in 2014. However, the High Court found that the delay of over ten years in issuing the charge memo was unjustified and could prejudice the respondent's defense. Despite arguments regarding the applicability of previous court decisions and the nature of the respondent's duties, the Court upheld the Tribunal's decision and dismissed the writ petition.
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