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...
Assessee filed second rectification application u/s 254, raising same grounds as first miscellaneous application which was already rejected. Tribunal held that except for certain documents, no evidence was available regarding payment of ESI and EPF within due dates as claimed. Second miscellaneous application filed within six months but on same grounds as first, hence not maintainable as per Smt. Vasantben H. Sheth case. Tribunal reiterated that Assessing Officer shall pass consequential order in compliance with Tribunal's order in Manikandan Vazhukkapara Kumaran case. Tribunal cannot entertain second miscellaneous application on same grounds after rejecting first.
Assessee filed second rectification application u/s 254, raising same grounds as first miscellaneous application which was already rejected. Tribunal held that except for certain documents, no evidence was available regarding payment of ESI and EPF within due dates as claimed. Second miscellaneous application filed within six months but on same grounds as first, hence not maintainable as per Smt. Vasantben H. Sheth case. Tribunal reiterated that Assessing Officer shall pass consequential order in compliance with Tribunal's order in Manikandan Vazhukkapara Kumaran case. Tribunal cannot entertain second miscellaneous application on same grounds after rejecting first.
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