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...
Petitioner sought limited relief to secure time for payment of admitted tax liabilities for specified assessment years; the HC, invoking the interest of justice and noting the petitioner's restricted request, granted a fourweek period for payment and disposed of the writ petition. The court directed payment of the admitted tax liabilities and remitted any remaining procedural action to the Assessing Officer insofar as recovery proceedings are concerned, effectively staying further recovery pending compliance with the payment direction.
Petitioner sought limited relief to secure time for payment of admitted tax liabilities for specified assessment years; the HC, invoking the interest of justice and noting the petitioner's restricted request, granted a fourweek period for payment and disposed of the writ petition. The court directed payment of the admitted tax liabilities and remitted any remaining procedural action to the Assessing Officer insofar as recovery proceedings are concerned, effectively staying further recovery pending compliance with the payment direction.
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