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...
Reliance on precedent by adjudicating authorities must be verified: the article identifies that reliance on non existent, incorrect or irrelevant judicial citations (apparently AI generated) breaches principles of natural justice and produces a procedural defect in reasoned orders; such unverified dependence indicates failure to apply independent judicial mind and can vitiate findings. It recommends prescribing parameters and directions to regulate how quasi judicial authorities rely on High Court and Supreme Court decisions, calls for institutional guidance (including Senior Standing Counsel assistance), and notes interim relief was granted pending formulation and final disposal.
Reliance on precedent by adjudicating authorities must be verified: the article identifies that reliance on non existent, incorrect or irrelevant judicial citations (apparently AI generated) breaches principles of natural justice and produces a procedural defect in reasoned orders; such unverified dependence indicates failure to apply independent judicial mind and can vitiate findings. It recommends prescribing parameters and directions to regulate how quasi judicial authorities rely on High Court and Supreme Court decisions, calls for institutional guidance (including Senior Standing Counsel assistance), and notes interim relief was granted pending formulation and final disposal.
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