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...
Forensic extraction from a director's mobile phone was treated as admissible without a separate section 138C certificate because the phone was recovered under panchnama and examined in context with the surrounding record. Rule 12 permitted rejection of declared transaction value where reasonable doubt arose from the director's statement and parallel invoices showing higher values, so re-determination of assessable value was upheld. Misdeclaration of value attracted confiscation under section 111(m), and the same undisclosed invoices justified invocation of the extended period under section 28(4). Differential duty and equal penalty under section 114A were sustained, but separate penalties under section 114AA were set aside.
Forensic extraction from a director's mobile phone was treated as admissible without a separate section 138C certificate because the phone was recovered under panchnama and examined in context with the surrounding record. Rule 12 permitted rejection of declared transaction value where reasonable doubt arose from the director's statement and parallel invoices showing higher values, so re-determination of assessable value was upheld. Misdeclaration of value attracted confiscation under section 111(m), and the same undisclosed invoices justified invocation of the extended period under section 28(4). Differential duty and equal penalty under section 114A were sustained, but separate penalties under section 114AA were set aside.
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