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 considered mandatory pre-deposit as a condition for entertaining a statutory appeal and found petitioner failed to comply despite personal hearings and specific directions, reflecting adversely on petitioner's conduct; combined with an unexplained and unreasonable delay in filing a writ challenging the appellate order, the court applied the doctrine that writs must be filed within a reasonable time and declined interference. Reliance was placed on relevant Supreme Court authorities regarding delay and laches. Writ petition dismissed for lack of merit due to non-deposit and inordinate delay.
High Court considered mandatory pre-deposit as a condition for entertaining a statutory appeal and found petitioner failed to comply despite personal hearings and specific directions, reflecting adversely on petitioner's conduct; combined with an unexplained and unreasonable delay in filing a writ challenging the appellate order, the court applied the doctrine that writs must be filed within a reasonable time and declined interference. Reliance was placed on relevant Supreme Court authorities regarding delay and laches. Writ petition dismissed for lack of merit due to non-deposit and inordinate delay.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4796
Join Channel
TaxTMI 
