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...
Suspension pending disciplinary inquiry is evaluated through a prima facie assessment of misconduct based on the chronology of events; the timeline showed an adverse inspection report pre-dating a fraudulent input tax credit claim, supporting initial misconduct findings. The article emphasises that departmental proceedings must be completed within specified timeframes with limited adjournments and that subsistence allowance during suspension is governed by applicable rules. Where a charge sheet has been issued, the Disciplinary Authority must proceed to conduct the departmental inquiry, and continuation of suspension is not warranted on the facts summarized.
Suspension pending disciplinary inquiry is evaluated through a prima facie assessment of misconduct based on the chronology of events; the timeline showed an adverse inspection report pre-dating a fraudulent input tax credit claim, supporting initial misconduct findings. The article emphasises that departmental proceedings must be completed within specified timeframes with limited adjournments and that subsistence allowance during suspension is governed by applicable rules. Where a charge sheet has been issued, the Disciplinary Authority must proceed to conduct the departmental inquiry, and continuation of suspension is not warranted on the facts summarized.
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