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...
Where an assessee files an application to withdraw an appeal, the Commissioner (Appeals) remains obliged to decide the appeal on its merits within the parameters of section 251(1)(a); dismissing the appeal in limine without merit-based consideration is contrary to that duty. The impugned CIT(A) order was set aside and all issues restored for de novo adjudication; CIT(A) must provide the assessee an opportunity to be heard and decide the appeal on merits. The appellate position is restored and the appeal is allowed for statistical purposes.
Where an assessee files an application to withdraw an appeal, the Commissioner (Appeals) remains obliged to decide the appeal on its merits within the parameters of section 251(1)(a); dismissing the appeal in limine without merit-based consideration is contrary to that duty. The impugned CIT(A) order was set aside and all issues restored for de novo adjudication; CIT(A) must provide the assessee an opportunity to be heard and decide the appeal on merits. The appellate position is restored and the appeal is allowed for statistical purposes.
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