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...
Garnishee notice directing provisional attachment of the petitioner's bank account was ordered withdrawn because the revenue authority failed to consider the petitioner's prior submissions and offered documents; immediate freezing was unjustified absent findings of deliberate evasion. The petitioner must submit requisite documents within ten days, and the department must examine them, invite clarification or hearing if needed, and decide the recovery question on merits within one month of submission; all contentions remain open pending that reconsideration.
Garnishee notice directing provisional attachment of the petitioner's bank account was ordered withdrawn because the revenue authority failed to consider the petitioner's prior submissions and offered documents; immediate freezing was unjustified absent findings of deliberate evasion. The petitioner must submit requisite documents within ten days, and the department must examine them, invite clarification or hearing if needed, and decide the recovery question on merits within one month of submission; all contentions remain open pending that reconsideration.
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