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 Assessment u/s 153A - no search conducted u/s 132 and 132A as against the petitioner - Incriminating material from laptop - Electronic evidence admissibility - The High court concluded that the proceedings initiated u/s 153A, including the assessment order and demand notice based on the flawed panchnama and unauthorized search, were without jurisdiction and authority. Consequently, the court quashed the notice, assessment order, and demand notice, declaring the proceedings non-est and void ab initio.
Validity of Assessment u/s 153A - no search conducted u/s 132 and 132A as against the petitioner - Incriminating material from laptop - Electronic evidence admissibility - The High court concluded that the proceedings initiated u/s 153A, including the assessment order and demand notice based on the flawed panchnama and unauthorized search, were without jurisdiction and authority. Consequently, the court quashed the notice, assessment order, and demand notice, declaring the proceedings non-est and void ab initio.
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