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...
Portal-only service of GST show-cause notices is insufficient where there is no acknowledgement of receipt or response to the notice. Similarly, uploading a contested order-in-original solely on the Common Portal does not commence the limitation period for filing an appeal. Taxpayers affected by notices or adjudication orders served only through the portal may seek the remedies available for defective service, including protection against limitation being calculated from the portal-upload date alone.
Portal-only service of GST show-cause notices is insufficient where there is no acknowledgement of receipt or response to the notice. Similarly, uploading a contested order-in-original solely on the Common Portal does not commence the limitation period for filing an appeal. Taxpayers affected by notices or adjudication orders served only through the portal may seek the remedies available for defective service, including protection against limitation being calculated from the portal-upload date alone.
Note: It is a system-generated summary and is for quick reference only.