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...
Petitioners did not make required pre-deposit for maintaining appeal - appeal initially filed belatedly, defective and rejected without merits - subsequent appeal filed with pre-deposit also belated - no lack of bona fide - petitioners already paid over 11% of disputed tax, more than required for appeal - matter remanded to appellate authority for decision on merits as substantial compliance with pre-deposit.
Petitioners did not make required pre-deposit for maintaining appeal - appeal initially filed belatedly, defective and rejected without merits - subsequent appeal filed with pre-deposit also belated - no lack of bona fide - petitioners already paid over 11% of disputed tax, more than required for appeal - matter remanded to appellate authority for decision on merits as substantial compliance with pre-deposit.
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