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 set aside CIT(Appeals)/NFAC's ex parte dismissal of assessee's appeal, holding that the appellate authority lacks power to summarily dismiss an appeal for non-prosecution. The tribunal mandated a de novo adjudication, requiring CIT(Appeals)/NFAC to examine the appeal's merits comprehensively under Section 251 of the Income Tax Act. The order directs the appellate authority to pass a reasoned order within three months, emphasizing the statutory obligation to apply judicial mind to all issues, while cautioning the assessee to comply with future hearing notices.
ITAT set aside CIT(Appeals)/NFAC's ex parte dismissal of assessee's appeal, holding that the appellate authority lacks power to summarily dismiss an appeal for non-prosecution. The tribunal mandated a de novo adjudication, requiring CIT(Appeals)/NFAC to examine the appeal's merits comprehensively under Section 251 of the Income Tax Act. The order directs the appellate authority to pass a reasoned order within three months, emphasizing the statutory obligation to apply judicial mind to all issues, while cautioning the assessee to comply with future hearing notices.
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