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...
Section 4A of the 1957 AP Sales Tax Act was treated as empowering a superior officer to exercise assessment powers without a separate jurisdictional order, so the Deputy Commissioner's assessment was upheld. The extended limitation under section 14(3) applied because the dealer produced accounts and related material after inspection, making the assessment timely. The dealer failed to discharge the section 6A burden to prove stock transfer or agency movement in the prescribed manner, so the transactions were treated as inter-State sales and the natural justice objection based on denial of cross-examination failed. Claims of double turnover addition and sales return deductions were rejected for want of proof, and penalty under the CST regime was sustained through the State penalty provision.
Section 4A of the 1957 AP Sales Tax Act was treated as empowering a superior officer to exercise assessment powers without a separate jurisdictional order, so the Deputy Commissioner's assessment was upheld. The extended limitation under section 14(3) applied because the dealer produced accounts and related material after inspection, making the assessment timely. The dealer failed to discharge the section 6A burden to prove stock transfer or agency movement in the prescribed manner, so the transactions were treated as inter-State sales and the natural justice objection based on denial of cross-examination failed. Claims of double turnover addition and sales return deductions were rejected for want of proof, and penalty under the CST regime was sustained through the State penalty provision.
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