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 - The High court found procedural lapses in invoking Section 153C against the petitioner without concrete evidence of undisclosed transactions for the relevant assessment year. It highlighted the absence of incriminating material specific to the petitioner for the year in question, rendering the invocation of Section 153C unjustifiable. - Reassessment under Section 148: The court clarified that proceedings under Section 148, aimed at reassessing income believed to have escaped assessment, could continue provided they were based on substantive evidence and not merely on the procedural fallout of a search operation targeting a different entity.
Assessment u/s 153C - The High court found procedural lapses in invoking Section 153C against the petitioner without concrete evidence of undisclosed transactions for the relevant assessment year. It highlighted the absence of incriminating material specific to the petitioner for the year in question, rendering the invocation of Section 153C unjustifiable. - Reassessment under Section 148: The court clarified that proceedings under Section 148, aimed at reassessing income believed to have escaped assessment, could continue provided they were based on substantive evidence and not merely on the procedural fallout of a search operation targeting a different entity.
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