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...
Non-service of show cause notice violated principles of natural justice. Respondent imposed tax liability without providing opportunity and documents to petitioner for defense. Court remanded matter to respondent for fresh consideration after petitioner pays 10% of disputed tax amount, setting aside earlier order to maintain consistency with previous cases allowing petitioner to present defense. Petition allowed by way of remand for reconsideration after partial tax payment by petitioner.
Non-service of show cause notice violated principles of natural justice. Respondent imposed tax liability without providing opportunity and documents to petitioner for defense. Court remanded matter to respondent for fresh consideration after petitioner pays 10% of disputed tax amount, setting aside earlier order to maintain consistency with previous cases allowing petitioner to present defense. Petition allowed by way of remand for reconsideration after partial tax payment by petitioner.
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