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...
Appeal dismissed due to filing beyond statutory limitation period. Petitioner's registration cancelled earlier, failed to avail amnesty scheme allowing restoration upon clearing dues. Petitioner not registered dealer during intervening period, activities unmonitored, transactions unascertainable. Petitioner did not controvert allegation of non-filing returns for six months. Law favors diligent, not indolent. Delay counted against petitioner. Petition dismissed.
Appeal dismissed due to filing beyond statutory limitation period. Petitioner's registration cancelled earlier, failed to avail amnesty scheme allowing restoration upon clearing dues. Petitioner not registered dealer during intervening period, activities unmonitored, transactions unascertainable. Petitioner did not controvert allegation of non-filing returns for six months. Law favors diligent, not indolent. Delay counted against petitioner. Petition dismissed.
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