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...
Service of a show cause notice solely by uploading it to the common portal was treated as ineffective where there was no acknowledgement of receipt or response from the assessee. An ex parte adjudication under Section 73 of the CGST Act founded on such notice could not be sustained because the assessee lacked an effective opportunity to reply. The ex parte order was set aside, with liberty to submit a response to the show cause notice. The competent authority must then conduct fresh adjudication and pass an order in accordance with law.
Service of a show cause notice solely by uploading it to the common portal was treated as ineffective where there was no acknowledgement of receipt or response from the assessee. An ex parte adjudication under Section 73 of the CGST Act founded on such notice could not be sustained because the assessee lacked an effective opportunity to reply. The ex parte order was set aside, with liberty to submit a response to the show cause notice. The competent authority must then conduct fresh adjudication and pass an order in accordance with law.
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