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...
All these show cause notices are speaking about the records from 01.04.2009 to 31.03.2010 which apparently and admittedly is not the period of demand in any of these show cause notices. The show cause notices are opined to be vague. - SCN of 2014 could rely upon the contents of the SCN of the year 2012 but later also a no detail except reliance upon SCN of 2008 which is not permissible - Resultantly, all four SCNs here are silent providing any basis to proceed against the appellant.
All these show cause notices are speaking about the records from 01.04.2009 to 31.03.2010 which apparently and admittedly is not the period of demand in any of these show cause notices. The show cause notices are opined to be vague. - SCN of 2014 could rely upon the contents of the SCN of the year 2012 but later also a no detail except reliance upon SCN of 2008 which is not permissible - Resultantly, all four SCNs here are silent providing any basis to proceed against the appellant.
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