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 applicant had suppressed material facts from the Authority for Advance Ruling by mis-declaring that the issue was not pending in any other proceedings, when in fact, proceedings on the same issue had already commenced by the DGGI. Upon being informed of this by the Appellant, the Authority for Advance Ruling declared the Ruling void ab initio u/s 104 of the Act. Consequently, the appeal filed by the Appellant before the Appellate Authority for Advance Ruling against the void Ruling became infructuous and was dismissed.
The applicant had suppressed material facts from the Authority for Advance Ruling by mis-declaring that the issue was not pending in any other proceedings, when in fact, proceedings on the same issue had already commenced by the DGGI. Upon being informed of this by the Appellant, the Authority for Advance Ruling declared the Ruling void ab initio u/s 104 of the Act. Consequently, the appeal filed by the Appellant before the Appellate Authority for Advance Ruling against the void Ruling became infructuous and was dismissed.
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