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...
Validity of penalty proceedings turned on whether the limitation period in clause (c) of Section 275(1) is residuary; the court held clause (c) is residuary and clauses (a) or (b) apply where penalty proceedings originate from an assessment or revision. Because the penalty under the special provision arose from an assessment linked to admissions during search and was appealed, the court applied the limitation computation under clause (a), measuring six months from receipt of the appellate tribunal order and finding the penalty issued on the final permissible date. Revision proceedings were quashed, so clause (b) did not apply, and the writ was dismissed.
Validity of penalty proceedings turned on whether the limitation period in clause (c) of Section 275(1) is residuary; the court held clause (c) is residuary and clauses (a) or (b) apply where penalty proceedings originate from an assessment or revision. Because the penalty under the special provision arose from an assessment linked to admissions during search and was appealed, the court applied the limitation computation under clause (a), measuring six months from receipt of the appellate tribunal order and finding the penalty issued on the final permissible date. Revision proceedings were quashed, so clause (b) did not apply, and the writ was dismissed.
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