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...
Challenge to provisional attachment order concerning bank account - pre-show cause notice issued - court held documents seized should be returned as petitioner is in real estate business and requires documents for operations - order of seizure not interfered with but respondents directed to return seized documents - regarding provisional bank attachment orders, in light of petitioner's contention of partial discharge of liability and interim stay by court, attachment orders set aside with liberty to respondents to proceed further after decision on show cause notice - petition partly allowed.
Challenge to provisional attachment order concerning bank account - pre-show cause notice issued - court held documents seized should be returned as petitioner is in real estate business and requires documents for operations - order of seizure not interfered with but respondents directed to return seized documents - regarding provisional bank attachment orders, in light of petitioner's contention of partial discharge of liability and interim stay by court, attachment orders set aside with liberty to respondents to proceed further after decision on show cause notice - petition partly allowed.
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