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 addressed the validity of an assessment u/s 153A and the jurisdiction for assessment proceedings transfer. The petitioner challenged the transfer from Sangli to Kozhikode, citing lack of mandatory notice and hearing u/s 127(2) and absence of a Document Identification Number (DIN) in the order. The Court found that notice was duly served, giving the petitioner an opportunity to respond, which was not utilized. The absence of DIN is being considered by the Supreme Court, but the transfer was deemed valid as the petitioner's business and recovery were within Kozhikode's jurisdiction. The Court dismissed the writ petition, finding no errors in the proceedings.
The High Court addressed the validity of an assessment u/s 153A and the jurisdiction for assessment proceedings transfer. The petitioner challenged the transfer from Sangli to Kozhikode, citing lack of mandatory notice and hearing u/s 127(2) and absence of a Document Identification Number (DIN) in the order. The Court found that notice was duly served, giving the petitioner an opportunity to respond, which was not utilized. The absence of DIN is being considered by the Supreme Court, but the transfer was deemed valid as the petitioner's business and recovery were within Kozhikode's jurisdiction. The Court dismissed the writ petition, finding no errors in the proceedings.
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