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...
Invalid approval for reassessment under the post-search regime vitiated the assessments, because the record did not show proper transmission of seized material to the approving authority and that factual gap remained unrebutted. The Tribunal also treated the assessments for the relevant years as wrongly framed under section 143(3), since after the search they fell within the post-search reassessment framework under sections 148/147, and quashed them on that basis. On the property issue, it accepted the seized document showing a lower investment figure and reduced the unexplained investment addition accordingly. On the cash issue, it directed verification of the company's taxed income and grant of telescoping to prevent double addition.
Invalid approval for reassessment under the post-search regime vitiated the assessments, because the record did not show proper transmission of seized material to the approving authority and that factual gap remained unrebutted. The Tribunal also treated the assessments for the relevant years as wrongly framed under section 143(3), since after the search they fell within the post-search reassessment framework under sections 148/147, and quashed them on that basis. On the property issue, it accepted the seized document showing a lower investment figure and reduced the unexplained investment addition accordingly. On the cash issue, it directed verification of the company's taxed income and grant of telescoping to prevent double addition.
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