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...
Section 161 allows an affected person to apply for rectification of an order. The authority had previously passed an order and decided no rectification was necessary, which the assessee felt adversely affected them. The High Court set aside that order, directing the authority to deal with the rectification application in accordance with law. The rectification process is separate from an appeal against the assessment order on merits, as provided for by the statute.
Section 161 allows an affected person to apply for rectification of an order. The authority had previously passed an order and decided no rectification was necessary, which the assessee felt adversely affected them. The High Court set aside that order, directing the authority to deal with the rectification application in accordance with law. The rectification process is separate from an appeal against the assessment order on merits, as provided for by the statute.
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