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 notice u/s 148 was time-barred under Section 149(1), rendering it invalid. The Assessing Officer (AO) exceeded statutory limitations by issuing a notice beyond the prescribed time period. The court emphasized that procedural timelines are mandatory and cannot be circumvented. The impugned notice was liable to be set aside solely on the ground of limitation, irrespective of other substantive challenges. The decision underscores the critical importance of adhering to statutory time constraints in tax reassessment proceedings, affirming that procedural compliance is essential for maintaining the integrity of tax assessment processes.
HC held that the notice u/s 148 was time-barred under Section 149(1), rendering it invalid. The Assessing Officer (AO) exceeded statutory limitations by issuing a notice beyond the prescribed time period. The court emphasized that procedural timelines are mandatory and cannot be circumvented. The impugned notice was liable to be set aside solely on the ground of limitation, irrespective of other substantive challenges. The decision underscores the critical importance of adhering to statutory time constraints in tax reassessment proceedings, affirming that procedural compliance is essential for maintaining the integrity of tax assessment processes.
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