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 valuation proceedings require the show-cause notice to identify the valuation rule on which the proposed demand rests. Where a notice invokes Rule 28(a), but the adjudicating authority finds that rule inapplicable and instead confirms the demand under Rule 27(c), the taxpayer must receive notice and an opportunity to respond to that distinct basis. Substituting the valuation rule at adjudication causes prejudice and breaches natural justice. A fresh show-cause notice is required before proceedings may be pursued on the revised valuation basis.
GST valuation proceedings require the show-cause notice to identify the valuation rule on which the proposed demand rests. Where a notice invokes Rule 28(a), but the adjudicating authority finds that rule inapplicable and instead confirms the demand under Rule 27(c), the taxpayer must receive notice and an opportunity to respond to that distinct basis. Substituting the valuation rule at adjudication causes prejudice and breaches natural justice. A fresh show-cause notice is required before proceedings may be pursued on the revised valuation basis.
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