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...
Second SCN issued pending adjudication of first SCN subsequently withdrawn - jurisdiction of first SCN challenged - withdrawal of first SCN after issuance of second SCN for differential amount not identical - second SCN within limitation period u/s 28(4) - opportunity to submit reply before authority - no error apparent - review to reagitate grounds already considered impermissible - review to raise new grounds not argued earlier impermissible - review dismissed.
Second SCN issued pending adjudication of first SCN subsequently withdrawn - jurisdiction of first SCN challenged - withdrawal of first SCN after issuance of second SCN for differential amount not identical - second SCN within limitation period u/s 28(4) - opportunity to submit reply before authority - no error apparent - review to reagitate grounds already considered impermissible - review to raise new grounds not argued earlier impermissible - review dismissed.
Note: It is a system-generated summary and is for quick reference only.