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...
In the matter under review, the High Court dismissed the review petitions filed by the parties. The Court held that no grounds were established for seeking a review of the order directing the refund of interest amount. The Court observed that the insufficient time to check calculations during the initial proceedings cannot be a ground for review. Regarding a letter from January 2014, which the Review Petitioner admitted was not brought to the Court's notice earlier, the Court stated that while it can be relied upon in the enquiry to fix responsibility for non-renewal of FD, it does not warrant a review of the Court's order. Consequently, both review petitions were dismissed by the High Court.
In the matter under review, the High Court dismissed the review petitions filed by the parties. The Court held that no grounds were established for seeking a review of the order directing the refund of interest amount. The Court observed that the insufficient time to check calculations during the initial proceedings cannot be a ground for review. Regarding a letter from January 2014, which the Review Petitioner admitted was not brought to the Court's notice earlier, the Court stated that while it can be relied upon in the enquiry to fix responsibility for non-renewal of FD, it does not warrant a review of the Court's order. Consequently, both review petitions were dismissed by the High Court.
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