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...
Registration u/s 12A - Rejection of petitioner's application u/s 119(2)(b) for delay in filing audit report in Form-10B. Held that petitioners are entitled to succeed. Delay in filing audit report in Form-10B can at best be 30 days, as law requires report to be uploaded at least a month before due date for filing returns. Considering extent of delay, Commissioner should have exercised jurisdiction u/s 119(2)(b) to condone delay instead of taking strict view. Relying on Al Jamia Mohammediyah Education Society case, writ petitions allowed by quashing orders dismissing petitioners' applications u/s 119(2)(b). Delay in filing audit report in Form-10B stands condoned.
Registration u/s 12A - Rejection of petitioner's application u/s 119(2)(b) for delay in filing audit report in Form-10B. Held that petitioners are entitled to succeed. Delay in filing audit report in Form-10B can at best be 30 days, as law requires report to be uploaded at least a month before due date for filing returns. Considering extent of delay, Commissioner should have exercised jurisdiction u/s 119(2)(b) to condone delay instead of taking strict view. Relying on Al Jamia Mohammediyah Education Society case, writ petitions allowed by quashing orders dismissing petitioners' applications u/s 119(2)(b). Delay in filing audit report in Form-10B stands condoned.
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