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...
Where immovable property was transferred under a registered agreement to sell cum irrevocable power of attorney, with full consideration received and possession already handed over, the Tribunal treated the sale proceeds as linked to that land and not as a separate basis for retaining equivalent-value attachment of other assets. It held that the Enforcement Directorate could proceed against the land itself after due process and notice to the buyer, and that the attached movable property was to be released if the appellants furnished an undertaking disclaiming any claim over the land; otherwise, the attachment would continue. The separate provisional attachment of seized cash was unsustained because no independent justification was shown.
Where immovable property was transferred under a registered agreement to sell cum irrevocable power of attorney, with full consideration received and possession already handed over, the Tribunal treated the sale proceeds as linked to that land and not as a separate basis for retaining equivalent-value attachment of other assets. It held that the Enforcement Directorate could proceed against the land itself after due process and notice to the buyer, and that the attached movable property was to be released if the appellants furnished an undertaking disclaiming any claim over the land; otherwise, the attachment would continue. The separate provisional attachment of seized cash was unsustained because no independent justification was shown.
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