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...
Adjudicatory treatment of tax liability for parking services must account for material documentary evidence and permit post decisional remedy: where an order rejected a claim that the petitioner acted for a municipal corporation because no Agreement was on file, the court granted liberty to tender supporting documents and required the proper officer to grant a post decisional hearing and decide thereafter; the impugned order was temporar ily held in abeyance and related garnishee proceedings stayed subject to strict filing and decision timetables, and the authority may record supplementary reasons if unconvinced.
Adjudicatory treatment of tax liability for parking services must account for material documentary evidence and permit post decisional remedy: where an order rejected a claim that the petitioner acted for a municipal corporation because no Agreement was on file, the court granted liberty to tender supporting documents and required the proper officer to grant a post decisional hearing and decide thereafter; the impugned order was temporar ily held in abeyance and related garnishee proceedings stayed subject to strict filing and decision timetables, and the authority may record supplementary reasons if unconvinced.
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