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...
When a statutory appellate forum is non-functional an aggrieved person may seek writ relief to avoid being remediless, but such relief cannot displace or relax statutory conditions attached to the statutory appeal. The note emphasises that where the appellate tribunal has been made functional and filing windows extended, disputes should be adjudicated by the designated forum. The pre-deposit condition requiring payment of the admitted amount and an additional portion of disputed tax remains binding and must be complied with before the appeal is entertained by the tribunal within the prescribed timeline.
When a statutory appellate forum is non-functional an aggrieved person may seek writ relief to avoid being remediless, but such relief cannot displace or relax statutory conditions attached to the statutory appeal. The note emphasises that where the appellate tribunal has been made functional and filing windows extended, disputes should be adjudicated by the designated forum. The pre-deposit condition requiring payment of the admitted amount and an additional portion of disputed tax remains binding and must be complied with before the appeal is entertained by the tribunal within the prescribed timeline.
Note: It is a system-generated summary and is for quick reference only.
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