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 held that the assessment reopening under SS147 was procedurally flawed. The AO failed to substantiate allegations of income escape by thoroughly examining disputed shipping bill evidence. The Assessee's contention of manual bill correction and non-involvement in alleged exports was not adequately addressed. Consequently, the SS148A(d) order was set aside, effectively nullifying the assessment reopening and upholding the Assessee's appeal without prejudice to potential future reassessment if concrete evidence emerges.
HC held that the assessment reopening under SS147 was procedurally flawed. The AO failed to substantiate allegations of income escape by thoroughly examining disputed shipping bill evidence. The Assessee's contention of manual bill correction and non-involvement in alleged exports was not adequately addressed. Consequently, the SS148A(d) order was set aside, effectively nullifying the assessment reopening and upholding the Assessee's appeal without prejudice to potential future reassessment if concrete evidence emerges.
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