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...
Challenge to blocking of Input Tax Credit under Rule 86A was rejected where inspection and recorded statements indicated availment of credit on disputed invoices; the impugned blocking was held to fall within the regulatory scheme and not amenable to interference. A jurisdictional objection that a subordinate officer effected the block was dismissed because blocking was shown to be authorised by senior officers. The court nevertheless granted liberty to the petitioner to make a representation and directed that the concerned officer hear the petitioner and decide the merits expeditiously, preferably within thirty days.
Challenge to blocking of Input Tax Credit under Rule 86A was rejected where inspection and recorded statements indicated availment of credit on disputed invoices; the impugned blocking was held to fall within the regulatory scheme and not amenable to interference. A jurisdictional objection that a subordinate officer effected the block was dismissed because blocking was shown to be authorised by senior officers. The court nevertheless granted liberty to the petitioner to make a representation and directed that the concerned officer hear the petitioner and decide the merits expeditiously, preferably within thirty days.
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