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...
Ratification of resignation acceptance validates separation retrospectively, while withdrawal may be refused through reasoned administrative discretio...
Turnover is a relevant comparability criterion in transfer pricing because scale affects profitability, risk profile, asset base, bargaining power and economies of scale; the Tribunal therefore upheld use of an upper turnover filter and rejected the Revenue's challenge to exclusion of high-turnover comparables. For inclusion of I2T2 India Limited and Cigniti Technologies Limited, the Tribunal held that a comparable cannot be adopted merely by relying on an earlier order without verifying contemporaneous financials, functional profile, applicable filters and segmental data for the year in question; that issue was remanded to the Assessing Officer/TPO for fresh examination after hearing the assessee.
Turnover is a relevant comparability criterion in transfer pricing because scale affects profitability, risk profile, asset base, bargaining power and economies of scale; the Tribunal therefore upheld use of an upper turnover filter and rejected the Revenue's challenge to exclusion of high-turnover comparables. For inclusion of I2T2 India Limited and Cigniti Technologies Limited, the Tribunal held that a comparable cannot be adopted merely by relying on an earlier order without verifying contemporaneous financials, functional profile, applicable filters and segmental data for the year in question; that issue was remanded to the Assessing Officer/TPO for fresh examination after hearing the assessee.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4817 
Join Channel 
