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...
Cancellation of petitioner's registration due to alleged fraud, willful misstatement, or suppression of facts in obtaining registration. Proper Officer issued show cause notice, but petitioner claimed non-disclosure of basis. Proper Officer clarified and provided documents. Petitioner filed response, but Proper Officer canceled registration on premise of non-reply. Matter remanded to Proper Officer for reconsideration of petitioner's case, taking note of response and affording opportunity of hearing. Petition disposed by way of remand.
Cancellation of petitioner's registration due to alleged fraud, willful misstatement, or suppression of facts in obtaining registration. Proper Officer issued show cause notice, but petitioner claimed non-disclosure of basis. Proper Officer clarified and provided documents. Petitioner filed response, but Proper Officer canceled registration on premise of non-reply. Matter remanded to Proper Officer for reconsideration of petitioner's case, taking note of response and affording opportunity of hearing. Petition disposed by way of remand.
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