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...
Non-disposal of an assessee's objections to reassessment reopening before completion of the assessment vitiates the reassessment, because disposal by a separate speaking order is a mandatory requirement and not a mere procedural formality. Applying its earlier decision in ITO v. Hardeep Singh, the ITAT held that the Assessing Officer had not decided the objections before finalising the reassessment. The annulment of the reassessment was therefore upheld, and the Revenue's reliance on Home Finders Housing Ltd. was not accepted.
Non-disposal of an assessee's objections to reassessment reopening before completion of the assessment vitiates the reassessment, because disposal by a separate speaking order is a mandatory requirement and not a mere procedural formality. Applying its earlier decision in ITO v. Hardeep Singh, the ITAT held that the Assessing Officer had not decided the objections before finalising the reassessment. The annulment of the reassessment was therefore upheld, and the Revenue's reliance on Home Finders Housing Ltd. was not accepted.
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