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...
Provisional attachment under the Act expires after one year, and an attachment directed by reference to a PAN does not automatically operate on a separate savings bank account absent a specific attachment order for that account; consequently the provisional attachment in relation to the petitioner's savings account is nonoperational as the oneyear period has lapsed. The High Court held that no justifying order specifically attaching the savings account appears on record, and therefore partly allowed the petition and disposed of pending applications accordingly.
Provisional attachment under the Act expires after one year, and an attachment directed by reference to a PAN does not automatically operate on a separate savings bank account absent a specific attachment order for that account; consequently the provisional attachment in relation to the petitioner's savings account is nonoperational as the oneyear period has lapsed. The High Court held that no justifying order specifically attaching the savings account appears on record, and therefore partly allowed the petition and disposed of pending applications accordingly.
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