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 HC dismissed the petition filed by the petitioner, a government company, against compulsory selection of its return for scrutiny by the Assessing Officer. The HC held that the CBDT guidelines for compulsory scrutiny did not preclude random selection by the AO. It rejected the contention of violation of natural justice, as the petitioner did not seek personal hearing while filing online reply. The HC found no reason to interfere under Article 226.
The HC dismissed the petition filed by the petitioner, a government company, against compulsory selection of its return for scrutiny by the Assessing Officer. The HC held that the CBDT guidelines for compulsory scrutiny did not preclude random selection by the AO. It rejected the contention of violation of natural justice, as the petitioner did not seek personal hearing while filing online reply. The HC found no reason to interfere under Article 226.
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