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...
After cancellation of GST registration, notices must be served through one of the alternative modes prescribed for service; mere uploading on the GST portal is insufficient and may offend natural justice in assessment proceedings. The text records that, on this basis, the writ petitions were disposed of in line with an earlier High Court view, while leaving the competent authority free to recommence proceedings from the show cause notice stage.
After cancellation of GST registration, notices must be served through one of the alternative modes prescribed for service; mere uploading on the GST portal is insufficient and may offend natural justice in assessment proceedings. The text records that, on this basis, the writ petitions were disposed of in line with an earlier High Court view, while leaving the competent authority free to recommence proceedings from the show cause notice stage.
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