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...
Transitional input tax credit rejection was set aside because the order was passed before expiry of the time given to reply to the show cause notice, depriving the taxpayer of an effective opportunity to place its explanation and supporting documents. The HC treated this as a clear breach of natural justice rather than a ruling on entitlement to the credit. The impugned order was quashed and the matter remitted for fresh consideration on merits after receipt of the reply and after affording a hearing.
Transitional input tax credit rejection was set aside because the order was passed before expiry of the time given to reply to the show cause notice, depriving the taxpayer of an effective opportunity to place its explanation and supporting documents. The HC treated this as a clear breach of natural justice rather than a ruling on entitlement to the credit. The impugned order was quashed and the matter remitted for fresh consideration on merits after receipt of the reply and after affording a hearing.
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