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 Assessing Officer's (AO) reopening of assessment under Section 147 was invalid. The AO's notice under Section 148A(d) exceeded the scope of original information, which suggested potential escaped income. The Assessee provided satisfactory explanations regarding TCS collection, cash deposits during demonetization, and time deposits. The court found no substantive evidence to support the reopening of assessment, thus setting aside the impugned notice and order. The decision emphasizes procedural fairness and the need for precise jurisdictional basis when reassessing tax liabilities.
The HC held that the Assessing Officer's (AO) reopening of assessment under Section 147 was invalid. The AO's notice under Section 148A(d) exceeded the scope of original information, which suggested potential escaped income. The Assessee provided satisfactory explanations regarding TCS collection, cash deposits during demonetization, and time deposits. The court found no substantive evidence to support the reopening of assessment, thus setting aside the impugned notice and order. The decision emphasizes procedural fairness and the need for precise jurisdictional basis when reassessing tax liabilities.
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