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 review petition filed u/s 114 read with Order XLVII Rule 1 of the Code of Civil Procedure, 1908 was dismissed as the petitioner failed to establish any mistake or error apparent on the face of the record. The impugned order was passed in the presence of the learned counsels without objection, and being an appealable order, the High Court did not find any grounds for review. The review petition lacked merit and was consequently dismissed.
The review petition filed u/s 114 read with Order XLVII Rule 1 of the Code of Civil Procedure, 1908 was dismissed as the petitioner failed to establish any mistake or error apparent on the face of the record. The impugned order was passed in the presence of the learned counsels without objection, and being an appealable order, the High Court did not find any grounds for review. The review petition lacked merit and was consequently dismissed.
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