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 article addresses the requirement that assumption of jurisdiction under section 153C requires a contemporaneous, written and year specific satisfaction by the Assessing Officer linking seized material to each assessment year; consolidated or blanket satisfaction spanning multiple years without year wise nexus is legally insufficient. Applying this principle, assessments founded on such undifferentiated satisfaction notes are unsustainable and liable to be quashed as void ab initio where no year specific incriminating material is shown to relate to the assessee for the years under consideration.
The article addresses the requirement that assumption of jurisdiction under section 153C requires a contemporaneous, written and year specific satisfaction by the Assessing Officer linking seized material to each assessment year; consolidated or blanket satisfaction spanning multiple years without year wise nexus is legally insufficient. Applying this principle, assessments founded on such undifferentiated satisfaction notes are unsustainable and liable to be quashed as void ab initio where no year specific incriminating material is shown to relate to the assessee for the years under consideration.
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