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 belated application for rectification under s.161 as time-barred but observed that, prima facie, the petitioner may fall within the exemption under Serial No.20 of N.N. 2/2017-CT (Rate); however, the factual question whether the petitioner dealt in goods covered by that entry was held to be inappropriate for determination by the HC. The court quashed the impugned order and remitted the matter to the original authority for fresh adjudication, directing adjudication on terms and specifying provisional compliance by the petitioner of 25% of the disputed tax. The petition was disposed of by remand.
The HC dismissed the belated application for rectification under s.161 as time-barred but observed that, prima facie, the petitioner may fall within the exemption under Serial No.20 of N.N. 2/2017-CT (Rate); however, the factual question whether the petitioner dealt in goods covered by that entry was held to be inappropriate for determination by the HC. The court quashed the impugned order and remitted the matter to the original authority for fresh adjudication, directing adjudication on terms and specifying provisional compliance by the petitioner of 25% of the disputed tax. The petition was disposed of by remand.
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