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...
Dispute concerns eligibility for the DTVSV Scheme, 2024 where the petitioner failed to deposit the amount specified in Form-3 and contends that this default triggers automatic revival of previously withdrawn revision petitions. The court applied the principle of automatic revival of prior adverse orders upon failure of a statutory declaration, restoring the parties to their pre-declaration positions and holding the respondents' refusal (based on no pending revision petitions) to be legally erroneous. The impugned order is set aside; petitioner is directed to approach respondents within thirty days to complete formalities to avail the scheme for tax arrears and penalty.
Dispute concerns eligibility for the DTVSV Scheme, 2024 where the petitioner failed to deposit the amount specified in Form-3 and contends that this default triggers automatic revival of previously withdrawn revision petitions. The court applied the principle of automatic revival of prior adverse orders upon failure of a statutory declaration, restoring the parties to their pre-declaration positions and holding the respondents' refusal (based on no pending revision petitions) to be legally erroneous. The impugned order is set aside; petitioner is directed to approach respondents within thirty days to complete formalities to avail the scheme for tax arrears and penalty.
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