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...
Revision under section 263 was held unsustainable because the Assessing Officer had properly examined the relevant material, accepted the assessee's project completion method, and adopted one permissible view on the taxability of on-money from the Spring-II project. The Court reiterated that revision is available only when the assessment order is both erroneous and prejudicial to the interests of the Revenue; a mere difference of opinion cannot justify interference where enquiries were made and the view taken was plausible. No material showed that the amount was taxable in the relevant assessment year, so the appeal was dismissed and no substantial question of law arose.
Revision under section 263 was held unsustainable because the Assessing Officer had properly examined the relevant material, accepted the assessee's project completion method, and adopted one permissible view on the taxability of on-money from the Spring-II project. The Court reiterated that revision is available only when the assessment order is both erroneous and prejudicial to the interests of the Revenue; a mere difference of opinion cannot justify interference where enquiries were made and the view taken was plausible. No material showed that the amount was taxable in the relevant assessment year, so the appeal was dismissed and no substantial question of law arose.
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