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 dismissed writ petition challenging provisional bank account attachment. Petitioner was granted hearing opportunity per earlier court directive and filed objections, which authorities rejected on October 30, 2024. Show cause notice under Sec. 74 was adjudicated with final order issued. Provisional attachment justified under Sec. 83 for one year until July 7, 2025. Court held petitioner has statutory alternative remedy to file appeal against Sec. 74 order. Petition dismissed with liberty to approach appellate authority according to law. Principles of natural justice not violated as reasoned order was passed after hearing petitioner's objections.
HC dismissed writ petition challenging provisional bank account attachment. Petitioner was granted hearing opportunity per earlier court directive and filed objections, which authorities rejected on October 30, 2024. Show cause notice under Sec. 74 was adjudicated with final order issued. Provisional attachment justified under Sec. 83 for one year until July 7, 2025. Court held petitioner has statutory alternative remedy to file appeal against Sec. 74 order. Petition dismissed with liberty to approach appellate authority according to law. Principles of natural justice not violated as reasoned order was passed after hearing petitioner's objections.
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