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...
Eligibility for settlement under DTVSV Act - Delay in filing appeal - Pending appeal before ITAT - Specified date under DTVSV Act - The High Court observed that Section 2 (1) (a) (ii) of the DTVSV Act includes cases where the time limit for filing an appeal had not expired on the specified date, making the assessee eligible for settlement benefits. - The DTVSV Act is aimed at resolving tax disputes and ensuring timely revenue collection. The specified date is 31.01.2020. The legislative intent, as evident from the Finance Minister’s speech and the Statement of Objects and Reasons, was to bring finality to tax disputes and reduce litigation. Thus, the interpretation of the DTVSV Act should be liberal and purposive, extending its benefits to eligible taxpayers. - The Delhi High Court ruled in favor of the assessee, allowing the application under the DTVSV Act.
Eligibility for settlement under DTVSV Act - Delay in filing appeal - Pending appeal before ITAT - Specified date under DTVSV Act - The High Court observed that Section 2 (1) (a) (ii) of the DTVSV Act includes cases where the time limit for filing an appeal had not expired on the specified date, making the assessee eligible for settlement benefits. - The DTVSV Act is aimed at resolving tax disputes and ensuring timely revenue collection. The specified date is 31.01.2020. The legislative intent, as evident from the Finance Minister’s speech and the Statement of Objects and Reasons, was to bring finality to tax disputes and reduce litigation. Thus, the interpretation of the DTVSV Act should be liberal and purposive, extending its benefits to eligible taxpayers. - The Delhi High Court ruled in favor of the assessee, allowing the application under the DTVSV Act.
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