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 reopening/reassessment - The tribunal found that the reasons recorded by the AO for reopening the assessment were not sufficient and valid, as they merely called for detailed verification and enquiry. Relying on the judicial precedents of PCIT vs. Manzil Dinesh Kumar Shah and PCIT vs. Maheswari Devi, the tribunal concluded that such reasons do not meet the statutory requirements for reopening. Consequently, the reassessment was quashed, rendering other issues academic.
Validity of reopening/reassessment - The tribunal found that the reasons recorded by the AO for reopening the assessment were not sufficient and valid, as they merely called for detailed verification and enquiry. Relying on the judicial precedents of PCIT vs. Manzil Dinesh Kumar Shah and PCIT vs. Maheswari Devi, the tribunal concluded that such reasons do not meet the statutory requirements for reopening. Consequently, the reassessment was quashed, rendering other issues academic.
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