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...
Petition challenging assessment order and consequential bank attachment was allowed. Impugned order imposing tax liability on allegation of sale suppression based on purchase-outward supply value difference was set aside. Petitioner claimed unawareness of proceedings due to non-receipt of show cause notice. Considering petitioner's assertion and nature of confirmed tax proposal, reconsideration warranted by remitting 5% of disputed tax demand within two weeks and submitting reply to show cause notice within said period. Petition disposed of.
Petition challenging assessment order and consequential bank attachment was allowed. Impugned order imposing tax liability on allegation of sale suppression based on purchase-outward supply value difference was set aside. Petitioner claimed unawareness of proceedings due to non-receipt of show cause notice. Considering petitioner's assertion and nature of confirmed tax proposal, reconsideration warranted by remitting 5% of disputed tax demand within two weeks and submitting reply to show cause notice within said period. Petition disposed of.
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