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...
Appellate authority failed to apply independent mind by paraphrasing the adjudicating authority and neglecting the petitioner's explanations and documents on record; the HC found the appellate order uninformed and susceptible to judicial reproach. The court held that the appellate order does not reveal consideration of submissions or file documents and therefore set aside the impugned order and remanded the matter for fresh merits consideration by the appellate authority, directing proper examination of the petitioner's grounds and documents on record.
Appellate authority failed to apply independent mind by paraphrasing the adjudicating authority and neglecting the petitioner's explanations and documents on record; the HC found the appellate order uninformed and susceptible to judicial reproach. The court held that the appellate order does not reveal consideration of submissions or file documents and therefore set aside the impugned order and remanded the matter for fresh merits consideration by the appellate authority, directing proper examination of the petitioner's grounds and documents on record.
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