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...
Jurisdiction - power of Joint Commissioner (Investigation) Enforcement to exercise powers and functions of adjudicating authority - The State argues notifications should be read together, designating the Joint Commissioner as a proper officer for statewide jurisdiction. Respondent No. 1 argues the notification grants blanket powers statewide. The court finds the proper officer for adjudication must be designated, emphasizing jurisdictional limits in the notification. None of the notifications extend jurisdiction beyond the designated area. The court agrees with the petitioner's contention, restraining coercive actions and granting time for responses. - The matter is scheduled for further proceedings.
Jurisdiction - power of Joint Commissioner (Investigation) Enforcement to exercise powers and functions of adjudicating authority - The State argues notifications should be read together, designating the Joint Commissioner as a proper officer for statewide jurisdiction. Respondent No. 1 argues the notification grants blanket powers statewide. The court finds the proper officer for adjudication must be designated, emphasizing jurisdictional limits in the notification. None of the notifications extend jurisdiction beyond the designated area. The court agrees with the petitioner's contention, restraining coercive actions and granting time for responses. - The matter is scheduled for further proceedings.
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