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...
Deductions u/s 80IC - audit report in Form 10 CCB, due to inadvertence, had not been uploaded online on time - Power of CBDT to condone delay us 119 - Rectification u/s 154 - The High Court observed that the tax authority's failure to act on the rectification request for nearly six years constituted an unreasonable refusal to exercise its statutory powers, thereby violating its duty. Errors made by the petitioner’s Chartered Accountants should not prejudice the petitioner's entitlement to statutory deductions, echoing the principle that the objective of the law is not to penalize taxpayers for inadvertent errors. The court rejected a narrow interpretation of 'genuine hardship' that would only consider severe financial crises, highlighting that the loss of statutory benefits itself constitutes a genuine hardship.
Deductions u/s 80IC - audit report in Form 10 CCB, due to inadvertence, had not been uploaded online on time - Power of CBDT to condone delay us 119 - Rectification u/s 154 - The High Court observed that the tax authority's failure to act on the rectification request for nearly six years constituted an unreasonable refusal to exercise its statutory powers, thereby violating its duty. Errors made by the petitioner’s Chartered Accountants should not prejudice the petitioner's entitlement to statutory deductions, echoing the principle that the objective of the law is not to penalize taxpayers for inadvertent errors. The court rejected a narrow interpretation of 'genuine hardship' that would only consider severe financial crises, highlighting that the loss of statutory benefits itself constitutes a genuine hardship.
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