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 adjudicated a tax assessment case involving reopening of assessment and accounting method challenges. The tribunal rejected the assessee's contentions regarding section 148 notice invalidity, confirming the notice's proper signing. The assessment reopening was deemed justifiable, with prior sanction under section 151 being procedurally valid. Regarding books of accounts, ITAT found the Assessing Officer's rejection warranted due to lack of stock register and verification challenges. The tribunal partially allowed the ground, remanding the net commission calculation issue to the AO for further verification with VAT authorities, mandating an opportunity of hearing and adherence to natural justice principles.
ITAT adjudicated a tax assessment case involving reopening of assessment and accounting method challenges. The tribunal rejected the assessee's contentions regarding section 148 notice invalidity, confirming the notice's proper signing. The assessment reopening was deemed justifiable, with prior sanction under section 151 being procedurally valid. Regarding books of accounts, ITAT found the Assessing Officer's rejection warranted due to lack of stock register and verification challenges. The tribunal partially allowed the ground, remanding the net commission calculation issue to the AO for further verification with VAT authorities, mandating an opportunity of hearing and adherence to natural justice principles.
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