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...
Faceless assessment procedure requires necessary enquiry, verification and collection of relevant information before issuing a show cause notice, with reasoned consideration of explanations and reconciliations. Blanket notices and additions that disregard disclosed Category III AIF redemption proceeds or explained unlisted-share sale proceeds, including reliance on unrequested purchaser-source details, demonstrate arbitrariness and non-application of mind. Effective personal hearing is also required: a same-day hearing notice and an unresolved video-conference failure deny natural justice. These defects vitiated the assessment, consequential demand and penalty notices, requiring fresh proceedings, a hearing on at least five working days' notice before any adverse order, and a speaking, reasoned order.
Faceless assessment procedure requires necessary enquiry, verification and collection of relevant information before issuing a show cause notice, with reasoned consideration of explanations and reconciliations. Blanket notices and additions that disregard disclosed Category III AIF redemption proceeds or explained unlisted-share sale proceeds, including reliance on unrequested purchaser-source details, demonstrate arbitrariness and non-application of mind. Effective personal hearing is also required: a same-day hearing notice and an unresolved video-conference failure deny natural justice. These defects vitiated the assessment, consequential demand and penalty notices, requiring fresh proceedings, a hearing on at least five working days' notice before any adverse order, and a speaking, reasoned order.
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