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...
Assessment against non existent company - name of company struck off by ROC - Assessment based on Seized Materials - The Tribunal noted that the Assessing Officer was aware of the company's non-existence but proceeded with the assessment. It ruled that the assessment orders passed in the name of a non-existing company were void ab initio, as they lacked jurisdictional validity. Consequently, the Tribunal quashed the entire assessment proceedings and allowed the cross objections filed by the assessee, dismissing the appeals filed by the Revenue.
Assessment against non existent company - name of company struck off by ROC - Assessment based on Seized Materials - The Tribunal noted that the Assessing Officer was aware of the company's non-existence but proceeded with the assessment. It ruled that the assessment orders passed in the name of a non-existing company were void ab initio, as they lacked jurisdictional validity. Consequently, the Tribunal quashed the entire assessment proceedings and allowed the cross objections filed by the assessee, dismissing the appeals filed by the Revenue.
Note: It is a system-generated summary and is for quick reference only.