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 note addresses the legal sufficiency of an electronically uploaded assessment order and its summary carrying a Reference Number / Document Identification Number as proof of digital authentication; the Reference Number is treated as exclusively assigned to that order, supporting its validity. It also treats unexplained delay in approaching the court (laches) as fatal to relief where no explanation is offered; the procedural consequence is that challenges to such orders may be dismissed for laches when the petitioner accessed the portal but did not promptly seek judicial review.
The note addresses the legal sufficiency of an electronically uploaded assessment order and its summary carrying a Reference Number / Document Identification Number as proof of digital authentication; the Reference Number is treated as exclusively assigned to that order, supporting its validity. It also treats unexplained delay in approaching the court (laches) as fatal to relief where no explanation is offered; the procedural consequence is that challenges to such orders may be dismissed for laches when the petitioner accessed the portal but did not promptly seek judicial review.
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