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...
Territorial jurisdiction of CMM assessed. DRT has jurisdiction to determine if secured creditor's enforcement of security is as per Act. CMM has authority to take possession of secured asset within jurisdiction, but impugned order without jurisdiction as property situated outside CMM's territorial limits. Petitioner ought to approach DRT u/s 17 of SARFAESI Act. Impugned order suspended for one week to approach DRT. Petition disposed of.
Territorial jurisdiction of CMM assessed. DRT has jurisdiction to determine if secured creditor's enforcement of security is as per Act. CMM has authority to take possession of secured asset within jurisdiction, but impugned order without jurisdiction as property situated outside CMM's territorial limits. Petitioner ought to approach DRT u/s 17 of SARFAESI Act. Impugned order suspended for one week to approach DRT. Petition disposed of.
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