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 granted relief in goods detention case, directing respondents to release detained conveyance and goods upon petitioner depositing 25% of goods value (Rs. 2,56,965) and furnishing bank guarantee for 75% (Rs. 7,70,895), along with executing a personal bond for remaining demand. The court's decision was based on petitioner's specific submissions and aligned with precedential judicial interpretation, effectively resolving the dispute by imposing conditional release mechanisms that balance statutory compliance and procedural fairness.
HC granted relief in goods detention case, directing respondents to release detained conveyance and goods upon petitioner depositing 25% of goods value (Rs. 2,56,965) and furnishing bank guarantee for 75% (Rs. 7,70,895), along with executing a personal bond for remaining demand. The court's decision was based on petitioner's specific submissions and aligned with precedential judicial interpretation, effectively resolving the dispute by imposing conditional release mechanisms that balance statutory compliance and procedural fairness.
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