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...
Maintainability of petition challenged on different cause of action. Petitioner claimed refund/Input Tax Credit for purchase of goods utilized in manufacturing and export of garments from September 2019 to January 2020. Though Special Appeal pending before Court on writ petition, cause of action different. Writ petition disposed, directing petitioner to approach appellate authority against impugned orders.
Maintainability of petition challenged on different cause of action. Petitioner claimed refund/Input Tax Credit for purchase of goods utilized in manufacturing and export of garments from September 2019 to January 2020. Though Special Appeal pending before Court on writ petition, cause of action different. Writ petition disposed, directing petitioner to approach appellate authority against impugned orders.
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