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 154 rectification order reversing previous order on allowance of depreciation on non-compete fee cannot be invoked when the issue is debatable. Primary issue pending consideration before Supreme Court. Jurisdictional High Court admitted whether Section 154 powers can be exercised when the issue is debatable in assessee's own case for earlier assessment year. Considering High Court admission of identical question in assessee's case, for judicial discipline and propriety, impugned order set aside, issue restored to CIT(Appeals) to decide after outcome of assessee's own case for AY 2012-13 and pass order accordingly. Appeal allowed for statistical purposes.
Section 154 rectification order reversing previous order on allowance of depreciation on non-compete fee cannot be invoked when the issue is debatable. Primary issue pending consideration before Supreme Court. Jurisdictional High Court admitted whether Section 154 powers can be exercised when the issue is debatable in assessee's own case for earlier assessment year. Considering High Court admission of identical question in assessee's case, for judicial discipline and propriety, impugned order set aside, issue restored to CIT(Appeals) to decide after outcome of assessee's own case for AY 2012-13 and pass order accordingly. Appeal allowed for statistical purposes.
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