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...
Where reopening rested solely on incriminating material seized in a search on another person, the special search assessment mechanism under section 153C prevailed over general reassessment under sections 147/148, and the reassessment was held bad in law. In the absence of the searched person's Assessing Officer's satisfaction note and any independent post-search material, jurisdiction under sections 147/148 could not be assumed on third-party search material alone. The objection of borrowed satisfaction was rejected because the Assessing Officer had issued notice, sought an explanation under section 148A(b), and passed a reasoned order under section 148A(d), showing independent application of mind.
Where reopening rested solely on incriminating material seized in a search on another person, the special search assessment mechanism under section 153C prevailed over general reassessment under sections 147/148, and the reassessment was held bad in law. In the absence of the searched person's Assessing Officer's satisfaction note and any independent post-search material, jurisdiction under sections 147/148 could not be assumed on third-party search material alone. The objection of borrowed satisfaction was rejected because the Assessing Officer had issued notice, sought an explanation under section 148A(b), and passed a reasoned order under section 148A(d), showing independent application of mind.
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