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...
The High Court adjudicated a matter concerning refund of an amount deposited under compulsion and provisional attachment of bank accounts. The court refrained from issuing directions for refund, clarifying that the petitioners could apply for refund in accordance with law without awaiting adjudication of the show cause notice. Regarding seized articles and documents, the respondent stated that all hard disks and other articles were returned, except two laptops which were stolen, with an FIR lodged for the same. The petition was consequently disposed of.
The High Court adjudicated a matter concerning refund of an amount deposited under compulsion and provisional attachment of bank accounts. The court refrained from issuing directions for refund, clarifying that the petitioners could apply for refund in accordance with law without awaiting adjudication of the show cause notice. Regarding seized articles and documents, the respondent stated that all hard disks and other articles were returned, except two laptops which were stolen, with an FIR lodged for the same. The petition was consequently disposed of.
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