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...
Validity of assessment order - Section 25(1) of KVAT Act - when issues of re-assessment are fairly complex and the financial implication resulting from the proposed assessment is substantial as well then the argument that objections filed by petitioner do not warrant hearing, is subjective and R1 could not have assumed that hearing would be nothing but an empty formality - order passed without giving hearing on the objections is set aside
Validity of assessment order - Section 25(1) of KVAT Act - when issues of re-assessment are fairly complex and the financial implication resulting from the proposed assessment is substantial as well then the argument that objections filed by petitioner do not warrant hearing, is subjective and R1 could not have assumed that hearing would be nothing but an empty formality - order passed without giving hearing on the objections is set aside
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