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 allowed the petition, invalidating the reassessment notice. The court determined that the Assessing Officer lacked sufficient material to demonstrate income escaping assessment exceeding Rs. 50 lacs in AY 2013-14. The notice was found to be beyond the prescribed limitation period under Section 149(1)(a) and did not satisfy conditions under Section 149(1)(b). The court specifically noted no evidence of undisclosed transactions or income, rendering the reassessment notice procedurally and substantively unsustainable. Consequently, the impugned order and notice were set aside, providing relief to the assessee.
HC allowed the petition, invalidating the reassessment notice. The court determined that the Assessing Officer lacked sufficient material to demonstrate income escaping assessment exceeding Rs. 50 lacs in AY 2013-14. The notice was found to be beyond the prescribed limitation period under Section 149(1)(a) and did not satisfy conditions under Section 149(1)(b). The court specifically noted no evidence of undisclosed transactions or income, rendering the reassessment notice procedurally and substantively unsustainable. Consequently, the impugned order and notice were set aside, providing relief to the assessee.
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