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 held that the Tribunal erred in exercising jurisdiction u/s 254(2) to set aside the additions made by the AO regarding delayed payment of statutory dues like PF and ESIC amounts. This view was contrary to the SC's decision in Checkmate Services Pvt Ltd, which was rendered after the Tribunal's order. The HC agreed with the Tribunal's decision in ANI Integrated Services Ltd, which rejected the Revenue's application seeking rectification in light of Checkmate Services Pvt Ltd, considering the limited jurisdiction u/s 254(2) and Beghar Foundation.
The HC held that the Tribunal erred in exercising jurisdiction u/s 254(2) to set aside the additions made by the AO regarding delayed payment of statutory dues like PF and ESIC amounts. This view was contrary to the SC's decision in Checkmate Services Pvt Ltd, which was rendered after the Tribunal's order. The HC agreed with the Tribunal's decision in ANI Integrated Services Ltd, which rejected the Revenue's application seeking rectification in light of Checkmate Services Pvt Ltd, considering the limited jurisdiction u/s 254(2) and Beghar Foundation.
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