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...
ITAT allows statistical appeal, remanding trust registration case u/s 12AB back to CIT(E) for fresh adjudication. The tribunal provides the assessee an additional opportunity to submit requisite documents and argue the case, directing CIT(E) to reappraise the matter comprehensively. Both the primary registration appeal and consequential u/s 80G appeal are restored to CIT(E)'s file, with explicit instructions to provide adequate hearing opportunity and enable comprehensive document submission by the trust.
ITAT allows statistical appeal, remanding trust registration case u/s 12AB back to CIT(E) for fresh adjudication. The tribunal provides the assessee an additional opportunity to submit requisite documents and argue the case, directing CIT(E) to reappraise the matter comprehensively. Both the primary registration appeal and consequential u/s 80G appeal are restored to CIT(E)'s file, with explicit instructions to provide adequate hearing opportunity and enable comprehensive document submission by the trust.
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