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...
The HC allowed the writ petition challenging the impugned assessment order issued following notice in DRC 01, noting that the petitioner had already undergone an assessment for the same period by the State Tax Officer. The court held that the statutory scheme precludes duplication of assessment proceedings for the identical period. Consequently, the impugned order was set aside. However, the respondents were granted liberty to initiate appropriate proceedings to recover any differential amount within the framework of the earlier assessment, provided the statutory provisions permit such action.
The HC allowed the writ petition challenging the impugned assessment order issued following notice in DRC 01, noting that the petitioner had already undergone an assessment for the same period by the State Tax Officer. The court held that the statutory scheme precludes duplication of assessment proceedings for the identical period. Consequently, the impugned order was set aside. However, the respondents were granted liberty to initiate appropriate proceedings to recover any differential amount within the framework of the earlier assessment, provided the statutory provisions permit such action.
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