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-compliance with a remand direction requiring completion of penalty proceedings within 12 weeks rendered the reinitiated proceedings unsustainable. The record showed that no final order under the penalty provision had been passed within the stipulated period and no extension of time had been sought. Mere issuance of show-cause notices did not amount to compliance, especially where repeated requests for a hearing had not been effectively addressed. On that ground, the show-cause notices issued in continuation of the remand were quashed.
Non-compliance with a remand direction requiring completion of penalty proceedings within 12 weeks rendered the reinitiated proceedings unsustainable. The record showed that no final order under the penalty provision had been passed within the stipulated period and no extension of time had been sought. Mere issuance of show-cause notices did not amount to compliance, especially where repeated requests for a hearing had not been effectively addressed. On that ground, the show-cause notices issued in continuation of the remand were quashed.
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