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...
Non-speaking order - It is clear that the order of Tribunal is certainly a non-speaking order and the Tribunal failed to consider the grounds raised by the appellant. Merely reproduction of comments from the show cause notice or order-in-original is not sufficient for a Tribunal to dismiss the appeal filed by the appellant. Each and every ground raised should be sufficiently discussed by the Tribunal while passing any order, that too, upon recording the rival contentions raised by either parties before it. - HC
Non-speaking order - It is clear that the order of Tribunal is certainly a non-speaking order and the Tribunal failed to consider the grounds raised by the appellant. Merely reproduction of comments from the show cause notice or order-in-original is not sufficient for a Tribunal to dismiss the appeal filed by the appellant. Each and every ground raised should be sufficiently discussed by the Tribunal while passing any order, that too, upon recording the rival contentions raised by either parties before it. - HC
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