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...
High Court directed petitioner to file an appeal under the Finance Act, 1994 within fifteen days and ordered that if the appeal is filed within that period the appellate authority shall not raise limitation objection because a certified copy of the adjudication order was supplied; petitioner must file the certified copy with the Appellate Authority within seven days of receipt. Subject to statutory formalities (other than limitation), the appeal must be admitted and decided on merits; writ petition disposed of accordingly.
High Court directed petitioner to file an appeal under the Finance Act, 1994 within fifteen days and ordered that if the appeal is filed within that period the appellate authority shall not raise limitation objection because a certified copy of the adjudication order was supplied; petitioner must file the certified copy with the Appellate Authority within seven days of receipt. Subject to statutory formalities (other than limitation), the appeal must be admitted and decided on merits; writ petition disposed of accordingly.
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