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...
Revision petition u/s 264 by assessee - Claiming to act as a collection agent for borewell digging payments, the petitioner argued that the income was exaggerated and included expenditures paid to rig owners. Despite the petitioner's assertions, the High Court found insufficient evidence to support their claims and emphasized the need for comprehensive documentation to challenge the assessment under revisional jurisdiction. However, acknowledging the petitioner's request for another opportunity to present evidence, the court granted the writ petition, nullified the previous order, and instructed the petitioner to appear before the Commissioner of Income Tax with all necessary documents for reconsideration.
Revision petition u/s 264 by assessee - Claiming to act as a collection agent for borewell digging payments, the petitioner argued that the income was exaggerated and included expenditures paid to rig owners. Despite the petitioner's assertions, the High Court found insufficient evidence to support their claims and emphasized the need for comprehensive documentation to challenge the assessment under revisional jurisdiction. However, acknowledging the petitioner's request for another opportunity to present evidence, the court granted the writ petition, nullified the previous order, and instructed the petitioner to appear before the Commissioner of Income Tax with all necessary documents for reconsideration.
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