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...
Assessment passed u/s 143(3) read with Sections 143(3A) and 143(3B) - faceless assessment scheme - No doubt, in this case, such show cause notice along with a draft assessment order has been issued on 12.04.2021. However, the time extended to the assessee to avail of the options under the draft assessment order is insufficient, insofar as the petitioner has been called upon to avail one of the options set forth, by 14.04.2021. The show cause notice and the accompanying draft assessment order have been received by the petitioner by e-mail on 13.04.2021. Thus 24 hours is available to the petitioner to comply with the same. - Relief granted - HC
Assessment passed u/s 143(3) read with Sections 143(3A) and 143(3B) - faceless assessment scheme - No doubt, in this case, such show cause notice along with a draft assessment order has been issued on 12.04.2021. However, the time extended to the assessee to avail of the options under the draft assessment order is insufficient, insofar as the petitioner has been called upon to avail one of the options set forth, by 14.04.2021. The show cause notice and the accompanying draft assessment order have been received by the petitioner by e-mail on 13.04.2021. Thus 24 hours is available to the petitioner to comply with the same. - Relief granted - HC
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