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 a show cause notice under Section 74(1) is founded on documents from an earlier search and seizure, the noticee must be given effective access to the relied upon material to answer it. The Court held that the petitioners were entitled to inspection and/or extracts of all relied upon records, and that specific accounting data such as excel or tally files had to be supplied where relied upon and specifically requested. It limited the ruling to this procedural access issue, directed disclosure within the time fixed, allowed time to reply and a personal hearing, extended the adjudication period, and left all other challenges open.
Where a show cause notice under Section 74(1) is founded on documents from an earlier search and seizure, the noticee must be given effective access to the relied upon material to answer it. The Court held that the petitioners were entitled to inspection and/or extracts of all relied upon records, and that specific accounting data such as excel or tally files had to be supplied where relied upon and specifically requested. It limited the ruling to this procedural access issue, directed disclosure within the time fixed, allowed time to reply and a personal hearing, extended the adjudication period, and left all other challenges open.
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