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...
Violation of principles of natural justice by the respondents. Impugned order passed without giving opportunity to petitioner to reply to show cause notice. Non-receipt of documents hindered petitioner's reply. Respondents lost original documents admittedly taken from petitioner, prejudicing petitioner's rights - a serious matter requiring action. Commissioner directed to explain why disciplinary action should not be taken against him and concerned officers for losing documents. Order forwarded to CBIC, Principal Secretary, and Chief Commissioner for information and necessary action. Respondents to show cause for making false statement about not having records contradicted by Commissioner's affidavit stating documents received but lost. Matter adjourned.
Violation of principles of natural justice by the respondents. Impugned order passed without giving opportunity to petitioner to reply to show cause notice. Non-receipt of documents hindered petitioner's reply. Respondents lost original documents admittedly taken from petitioner, prejudicing petitioner's rights - a serious matter requiring action. Commissioner directed to explain why disciplinary action should not be taken against him and concerned officers for losing documents. Order forwarded to CBIC, Principal Secretary, and Chief Commissioner for information and necessary action. Respondents to show cause for making false statement about not having records contradicted by Commissioner's affidavit stating documents received but lost. Matter adjourned.
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