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 Settlement Commission orders - The case involved petitions seeking directives for the issuance of formal orders under section 245D (4) of the Income Tax Act, 1961, reflecting settlement terms pronounced by the Settlement Commission. While petitioners asserted the settlement's conclusion, respondent No. 2 contested, citing discrepancies in official records. - Upon review, the High Court found the affidavit of the Vice President and Member of the Settlement Commission to be conclusive evidence of settlement. Despite respondent No. 2's objections, the High Court directed the Interim Board to issue the requested orders, ensuring the proper administration of justice.
Validity of Settlement Commission orders - The case involved petitions seeking directives for the issuance of formal orders under section 245D (4) of the Income Tax Act, 1961, reflecting settlement terms pronounced by the Settlement Commission. While petitioners asserted the settlement's conclusion, respondent No. 2 contested, citing discrepancies in official records. - Upon review, the High Court found the affidavit of the Vice President and Member of the Settlement Commission to be conclusive evidence of settlement. Despite respondent No. 2's objections, the High Court directed the Interim Board to issue the requested orders, ensuring the proper administration of justice.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4801
Join Channel
TaxTMI 
