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 reviewed a challenge to an interim order requiring appellants to deposit 20% of the remaining unpaid interest within a specified timeframe. The court held that the statute governing appeals to the tribunal does not mandate payment of 20% of disputed interest, but rather 20% of the remaining tax amount in dispute. The court emphasized that statutory provisions should guide judicial discretion, leading to the conclusion that the condition imposed by the lower court was improper. As a result, the appeal was allowed.
The High Court reviewed a challenge to an interim order requiring appellants to deposit 20% of the remaining unpaid interest within a specified timeframe. The court held that the statute governing appeals to the tribunal does not mandate payment of 20% of disputed interest, but rather 20% of the remaining tax amount in dispute. The court emphasized that statutory provisions should guide judicial discretion, leading to the conclusion that the condition imposed by the lower court was improper. As a result, the appeal was allowed.
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