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...
Extension of time for filing the appeal granted until 16-3-2026 with express protection that if filed by that date the appeal shall not be dismissed on limitation and shall be adjudicated on merits; pre-deposit requirement for the statutory appeal does not preclude this relief as the petition is disposed of on that basis. The court declined to interfere with the impugned High Court order and disposed of the Special Leave Petition subject to the time-extension and non-dismissal on limitation safeguard.
Extension of time for filing the appeal granted until 16-3-2026 with express protection that if filed by that date the appeal shall not be dismissed on limitation and shall be adjudicated on merits; pre-deposit requirement for the statutory appeal does not preclude this relief as the petition is disposed of on that basis. The court declined to interfere with the impugned High Court order and disposed of the Special Leave Petition subject to the time-extension and non-dismissal on limitation safeguard.
Note: It is a system-generated summary and is for quick reference only.