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...
Natural justice justified writ interference where additional objections and supporting documents were refused in insolvency proceedings after the corporate debtor had filed its original reply. The Tribunal had power to receive subsequent pleadings with leave under the procedural rules, read with its inherent powers, and the refusal on the ground that no such provision existed was unsustainable. The short time for the original reply explained the later filing, and the alternative-remedy objection did not bar relief because the refusal was procedurally unfair. The impugned order was set aside and the Tribunal was directed to consider the additional objections and documents.
Natural justice justified writ interference where additional objections and supporting documents were refused in insolvency proceedings after the corporate debtor had filed its original reply. The Tribunal had power to receive subsequent pleadings with leave under the procedural rules, read with its inherent powers, and the refusal on the ground that no such provision existed was unsustainable. The short time for the original reply explained the later filing, and the alternative-remedy objection did not bar relief because the refusal was procedurally unfair. The impugned order was set aside and the Tribunal was directed to consider the additional objections and documents.
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