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 court allowed the application seeking permission to complete the assessment for the year 2019-20 in respect of the assessee petitioner. However, the court imposed a condition that if the assessment is adverse to the petitioner, it shall not be enforced and shall be subject to further orders on the petition. All contentions of the parties regarding the assessment were expressly kept open. The court's decision was based on a previous order passed by a coordinate bench in a similar case, where the state was permitted to proceed with the assessment for the year 2018-19 to avoid it becoming time-barred.
The court allowed the application seeking permission to complete the assessment for the year 2019-20 in respect of the assessee petitioner. However, the court imposed a condition that if the assessment is adverse to the petitioner, it shall not be enforced and shall be subject to further orders on the petition. All contentions of the parties regarding the assessment were expressly kept open. The court's decision was based on a previous order passed by a coordinate bench in a similar case, where the state was permitted to proceed with the assessment for the year 2018-19 to avoid it becoming time-barred.
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