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 GST assessment confirming a proposed demand was set aside where the adjudication was non-reasoned and did not meaningfully deal with the assessee's reply. Although the reply had been received and acknowledged, the order merely said it was not in order and that records were not produced, without a proper discussion of the objections; the assessment was quashed and remitted for fresh decision on merits. The text also notes that calling the assessee for personal hearing before requiring a reply was procedurally improper, and due notice and proper process were directed before any final order.
A GST assessment confirming a proposed demand was set aside where the adjudication was non-reasoned and did not meaningfully deal with the assessee's reply. Although the reply had been received and acknowledged, the order merely said it was not in order and that records were not produced, without a proper discussion of the objections; the assessment was quashed and remitted for fresh decision on merits. The text also notes that calling the assessee for personal hearing before requiring a reply was procedurally improper, and due notice and proper process were directed before any final order.
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