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...
Deduction under section 10A was allowed as an alternate claim even though the return had originally claimed section 10B, because Form 56F was furnished during assessment and the same units had already been allowed section 10A relief in earlier scrutiny years; in the absence of any material showing those earlier allowances were or revised, the Revenue could not deny eligibility in the later year. The Tribunal also held that the assessee failed to show that the assessment order was without jurisdiction, while the jurisdiction order under section 120 was on record, so the jurisdictional objection had no merit. The Revenue's appeal was rejected and the cross-objection was dismissed.
Deduction under section 10A was allowed as an alternate claim even though the return had originally claimed section 10B, because Form 56F was furnished during assessment and the same units had already been allowed section 10A relief in earlier scrutiny years; in the absence of any material showing those earlier allowances were or revised, the Revenue could not deny eligibility in the later year. The Tribunal also held that the assessee failed to show that the assessment order was without jurisdiction, while the jurisdiction order under section 120 was on record, so the jurisdictional objection had no merit. The Revenue's appeal was rejected and the cross-objection was dismissed.
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