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...
Mechanical approval for reassessment sanction under section 151, recorded only as "Yes", was held to show no proper application of mind and no statutory due satisfaction. Relying on the coordinate Bench view in Sandhya Sharma, the Tribunal found that such a perfunctory sanction vitiated the assumption of jurisdiction under sections 147/148. The reassessment initiation was therefore bad in law, and the assessment order was quashed on the jurisdictional ground.
Mechanical approval for reassessment sanction under section 151, recorded only as "Yes", was held to show no proper application of mind and no statutory due satisfaction. Relying on the coordinate Bench view in Sandhya Sharma, the Tribunal found that such a perfunctory sanction vitiated the assumption of jurisdiction under sections 147/148. The reassessment initiation was therefore bad in law, and the assessment order was quashed on the jurisdictional ground.
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