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 Income Tax Appellate Tribunal allowed the assessee's appeal for statistical purposes. It set aside the CIT(A)'s dismissal of the rectification application and directed the CIT(A) to decide the grounds of appeal raised by the assessee on merits as per Section 250(6) of the Act. The Tribunal held that the CIT(A)'s action of not interfering with the CPC's adjustment regarding GST/CENVAT refund on the ground of requiring verification of books of accounts was akin to "missing the woods for trees". The Tribunal emphasized that rules of procedure should promote justice, not obstruct it, relying on the Supreme Court's observation in MV Vali Perov. Fernandeo Lopez case.
The Income Tax Appellate Tribunal allowed the assessee's appeal for statistical purposes. It set aside the CIT(A)'s dismissal of the rectification application and directed the CIT(A) to decide the grounds of appeal raised by the assessee on merits as per Section 250(6) of the Act. The Tribunal held that the CIT(A)'s action of not interfering with the CPC's adjustment regarding GST/CENVAT refund on the ground of requiring verification of books of accounts was akin to "missing the woods for trees". The Tribunal emphasized that rules of procedure should promote justice, not obstruct it, relying on the Supreme Court's observation in MV Vali Perov. Fernandeo Lopez case.
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