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...
Uploading a GST show cause notice under "Additional Notices" instead of "Notices and Orders" was held to be no proper service, so the ex parte adjudication order and recovery notice based on that notice were unsustainable for breach of natural justice. The impugned notice, adjudication order and recovery notice were quashed, with liberty to issue a fresh show cause notice and proceed afresh in accordance with law. The Court also clarified that limitation would not prevent issuance of a fresh notice in substitution of the earlier one.
Uploading a GST show cause notice under "Additional Notices" instead of "Notices and Orders" was held to be no proper service, so the ex parte adjudication order and recovery notice based on that notice were unsustainable for breach of natural justice. The impugned notice, adjudication order and recovery notice were quashed, with liberty to issue a fresh show cause notice and proceed afresh in accordance with law. The Court also clarified that limitation would not prevent issuance of a fresh notice in substitution of the earlier one.
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