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 Calcutta High Court reviewed the cancellation of the petitioner's registration due to alleged tax evasion. The court noted that the petitioner did not submit required documents but responded to a show cause notice. The rejection of the application for revocation was based on non-submission of purchase and sale statements. The court directed the cancellation to be revoked upon filing returns and documents as required. The orders of cancellation and rejection were set aside, contingent on the petitioner complying with tax obligations. The petition was disposed of accordingly.
The Calcutta High Court reviewed the cancellation of the petitioner's registration due to alleged tax evasion. The court noted that the petitioner did not submit required documents but responded to a show cause notice. The rejection of the application for revocation was based on non-submission of purchase and sale statements. The court directed the cancellation to be revoked upon filing returns and documents as required. The orders of cancellation and rejection were set aside, contingent on the petitioner complying with tax obligations. The petition was disposed of accordingly.
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