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...
HC upheld validity of assessment order under s.147 read with s.144B, finding proper approval under s.151. Court confirmed Range Head and CIT/PCIT had appropriately endorsed AO's recorded reasons for scrutiny notice under s.148. Review of computerized order details demonstrated requisite approvals obtained at each stage of faceless assessment. Finding no jurisdictional error, HC declined to exercise writ jurisdiction. Petitioner directed to pursue statutory appeal remedy for AY 2013-14, with time spent in writ proceedings eligible for consideration in any delay condonation application.
HC upheld validity of assessment order under s.147 read with s.144B, finding proper approval under s.151. Court confirmed Range Head and CIT/PCIT had appropriately endorsed AO's recorded reasons for scrutiny notice under s.148. Review of computerized order details demonstrated requisite approvals obtained at each stage of faceless assessment. Finding no jurisdictional error, HC declined to exercise writ jurisdiction. Petitioner directed to pursue statutory appeal remedy for AY 2013-14, with time spent in writ proceedings eligible for consideration in any delay condonation application.
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