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...
Consolidated show-cause notices covering multiple financial years are maintainable under Sections 73 and 74 of the CGST and SGST enactments, which do not prohibit clubbing tax periods in one notice. Quashing such a notice and consequential orders solely because multiple years were combined is unsustainable. An appellate authority must also provide an effective hearing on the merits where the appellant seeks condonation of delay and admission of the appeal for that purpose. Restricting the hearing to delay and deciding the appeal without a merits hearing breaches principles of natural justice. The appellate order was set aside and remitted for a merits hearing.
Consolidated show-cause notices covering multiple financial years are maintainable under Sections 73 and 74 of the CGST and SGST enactments, which do not prohibit clubbing tax periods in one notice. Quashing such a notice and consequential orders solely because multiple years were combined is unsustainable. An appellate authority must also provide an effective hearing on the merits where the appellant seeks condonation of delay and admission of the appeal for that purpose. Restricting the hearing to delay and deciding the appeal without a merits hearing breaches principles of natural justice. The appellate order was set aside and remitted for a merits hearing.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
