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...
The High Court considered a petition seeking revocation of a provisional attachment order u/s 281B of Fixed Deposit Receipts (FDRs). The ACIT (Hq) on behalf of PCIT (Central), Kanpur Nagar, approved the extension of the attachment. The assessee requested release of FDRs due to business hardship. The High Court order was referenced. The Ld. PCIT (Central) Kanpur revoked all provisional attachments u/s 281B. Immediate steps were directed for releasing the FDRs, with an action report due within a week. Corrective action was noted in response to the petition.
The High Court considered a petition seeking revocation of a provisional attachment order u/s 281B of Fixed Deposit Receipts (FDRs). The ACIT (Hq) on behalf of PCIT (Central), Kanpur Nagar, approved the extension of the attachment. The assessee requested release of FDRs due to business hardship. The High Court order was referenced. The Ld. PCIT (Central) Kanpur revoked all provisional attachments u/s 281B. Immediate steps were directed for releasing the FDRs, with an action report due within a week. Corrective action was noted in response to the petition.
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