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...
Provisional orders of attachment issued u/s 83 can be challenged by filing objection u/r 159(5). Petitioner did not file objection. Respondents issued fresh provisional attachment orders as notices u/s 74 could not be served on petitioner, who prima facie avoided service. Provisional attachment orders, though drastic, are permissible to protect revenue interest. Petitioner did not apply for release of property by filing objection u/r 159(5) even after fresh attachment orders. Inquiry u/s 74 is ongoing. At this stage, there appears material for provisional attachment orders. Petitioner did not approach respondents u/r 159(5) and did not explain non-approach. Petitioner not entitled to writ remedy. Petition dismissed.
Provisional orders of attachment issued u/s 83 can be challenged by filing objection u/r 159(5). Petitioner did not file objection. Respondents issued fresh provisional attachment orders as notices u/s 74 could not be served on petitioner, who prima facie avoided service. Provisional attachment orders, though drastic, are permissible to protect revenue interest. Petitioner did not apply for release of property by filing objection u/r 159(5) even after fresh attachment orders. Inquiry u/s 74 is ongoing. At this stage, there appears material for provisional attachment orders. Petitioner did not approach respondents u/r 159(5) and did not explain non-approach. Petitioner not entitled to writ remedy. Petition dismissed.
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