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...
Reopening of assessment - The Appellate Tribunal cited the CBDT's instruction clarifying the judgment of the Hon’ble Supreme Court, stating that notices cannot be issued for certain assessment years where the income escaping assessment is less than fifty lakh rupees. Since the escaped income in the present case was Rs. 29 Lacs falling below the threshold, the Tribunal quashed the notice issued u/s 148 of the Act.
Reopening of assessment - The Appellate Tribunal cited the CBDT's instruction clarifying the judgment of the Hon’ble Supreme Court, stating that notices cannot be issued for certain assessment years where the income escaping assessment is less than fifty lakh rupees. Since the escaped income in the present case was Rs. 29 Lacs falling below the threshold, the Tribunal quashed the notice issued u/s 148 of the Act.
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