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...
Transfer of case u/s 127 - sufficient material existed for transfer from Income Tax Office, Corporate Ward-2(3), Chennai to DCIT, Circle-4(4), Kolkata ('Central Circle'). Search and seizure u/s 132 revealed incriminating documents connecting petitioner's involvement in lottery business operations in West Bengal as sub-distributor, stockist, printing press, etc. Considering petitioner's reply, transfer ordered to centralize investigation along with eight other similar cases. Contentions of lack of opportunity or insufficient material rejected. Transfer for coordinated investigation in public interest permissible despite inconvenience. No prejudice caused as no adverse assessment order passed, only transfer u/s 127. Strict interpretation of taxing statute warranted. Writ petition dismissed.
Transfer of case u/s 127 - sufficient material existed for transfer from Income Tax Office, Corporate Ward-2(3), Chennai to DCIT, Circle-4(4), Kolkata ('Central Circle'). Search and seizure u/s 132 revealed incriminating documents connecting petitioner's involvement in lottery business operations in West Bengal as sub-distributor, stockist, printing press, etc. Considering petitioner's reply, transfer ordered to centralize investigation along with eight other similar cases. Contentions of lack of opportunity or insufficient material rejected. Transfer for coordinated investigation in public interest permissible despite inconvenience. No prejudice caused as no adverse assessment order passed, only transfer u/s 127. Strict interpretation of taxing statute warranted. Writ petition dismissed.
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