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 ITAT Pune set aside an ex-parte order by the CIT(A) due to improper service of hearing notice. The CIT(A) dismissed the appeal in limine for non-prosecution without discussing the merits of TP adjustment. The tribunal held that CIT(A) should have addressed the appeal's substance even in ex-parte cases, citing a precedent. The matter was remitted to CIT(A) for fresh consideration in accordance with the law.
The ITAT Pune set aside an ex-parte order by the CIT(A) due to improper service of hearing notice. The CIT(A) dismissed the appeal in limine for non-prosecution without discussing the merits of TP adjustment. The tribunal held that CIT(A) should have addressed the appeal's substance even in ex-parte cases, citing a precedent. The matter was remitted to CIT(A) for fresh consideration in accordance with the law.
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