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...
Application maintainability was questioned where the applicant initially failed to produce purchase and sales invoices and product brochure; the appellate power to confirm or modify an advance ruling exists but no merits determination was possible on the record. The applicant subsequently furnished invoices and offered further documents at hearing; those materials require factual verification and assessment for relevance. The appellate body set aside the impugned non maintainability ruling and remanded the matter to the Advance Ruling Authority for fresh examination and decision in light of the newly produced records.
Application maintainability was questioned where the applicant initially failed to produce purchase and sales invoices and product brochure; the appellate power to confirm or modify an advance ruling exists but no merits determination was possible on the record. The applicant subsequently furnished invoices and offered further documents at hearing; those materials require factual verification and assessment for relevance. The appellate body set aside the impugned non maintainability ruling and remanded the matter to the Advance Ruling Authority for fresh examination and decision in light of the newly produced records.
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