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 dismissed the writ challenging a suo motu revision order by an Additional Commissioner under s.23(4)(a) of the OST Act, holding the Additional Commissioner validly exercised delegated revisionary power and that the Commissioner lacked jurisdiction to re-initiate revision once such delegated power was exercised. By virtue of the non-obstante clause in s.23(4)(d) and the delegation scheme under s.3/Rule 3, any remedy lies by way of appeal to the Commissioner under s.23(4)(c)(ii). The petitioner was directed to pursue the statutory appellate remedy against the order dated 31 May 2025 before the Commissioner and may raise all available grounds; the writ petition was disposed.
The HC dismissed the writ challenging a suo motu revision order by an Additional Commissioner under s.23(4)(a) of the OST Act, holding the Additional Commissioner validly exercised delegated revisionary power and that the Commissioner lacked jurisdiction to re-initiate revision once such delegated power was exercised. By virtue of the non-obstante clause in s.23(4)(d) and the delegation scheme under s.3/Rule 3, any remedy lies by way of appeal to the Commissioner under s.23(4)(c)(ii). The petitioner was directed to pursue the statutory appellate remedy against the order dated 31 May 2025 before the Commissioner and may raise all available grounds; the writ petition was disposed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4800
Join Channel
TaxTMI 
