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...
GST show cause notices served only through the portal after cancellation of registration do not constitute effective service where the taxpayer cannot access the portal. Adjudication based on such service is liable to be set aside, with the tax authorities permitted to restart proceedings from the show cause notice stage in accordance with law. In fresh proceedings, a personal hearing must be provided where the taxpayer requests it under the statutory requirement. The discussion relies on decisions treating portal-only communication after cancellation as inconsistent with effective notice and procedural fairness.
GST show cause notices served only through the portal after cancellation of registration do not constitute effective service where the taxpayer cannot access the portal. Adjudication based on such service is liable to be set aside, with the tax authorities permitted to restart proceedings from the show cause notice stage in accordance with law. In fresh proceedings, a personal hearing must be provided where the taxpayer requests it under the statutory requirement. The discussion relies on decisions treating portal-only communication after cancellation as inconsistent with effective notice and procedural fairness.
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