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 ruled that the block period of six years for reassessment under Section 153C(1)(b) is to be calculated from 28.07.2022. The extended ten-year period is inapplicable in this case. The jurisdictional notice for Assessment Year 2016-17, falling beyond the six-year block period, was deemed unsustainable. Relying on prior judicial precedent, the court set aside the impugned notice, effectively invalidating the tax department's attempt to reopen the assessment beyond the prescribed statutory timeframe.
HC ruled that the block period of six years for reassessment under Section 153C(1)(b) is to be calculated from 28.07.2022. The extended ten-year period is inapplicable in this case. The jurisdictional notice for Assessment Year 2016-17, falling beyond the six-year block period, was deemed unsustainable. Relying on prior judicial precedent, the court set aside the impugned notice, effectively invalidating the tax department's attempt to reopen the assessment beyond the prescribed statutory timeframe.
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