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...
A miscellaneous application filed after disposal was held maintainable only for correction of clerical or arithmetical errors, or in exceptional cases where an executory order becomes impossible because of later events; it could not be used to rewrite the final order, and was dismissed as a disguised review and abuse of process. The Court also held that the signed order uploaded after chamber corrections alone constituted the final operative order. Changes from the dictated draft, including disposal with liberty to pursue remedies and omission of a status quo direction, were treated as permissible refinement and correction rather than material alteration requiring rehearing.
A miscellaneous application filed after disposal was held maintainable only for correction of clerical or arithmetical errors, or in exceptional cases where an executory order becomes impossible because of later events; it could not be used to rewrite the final order, and was dismissed as a disguised review and abuse of process. The Court also held that the signed order uploaded after chamber corrections alone constituted the final operative order. Changes from the dictated draft, including disposal with liberty to pursue remedies and omission of a status quo direction, were treated as permissible refinement and correction rather than material alteration requiring rehearing.
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