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...
Service of SCN - SCN not sent at proper address - The department was fully aware that the appellant is not residing and not available in the address - After the Show Cause Notice was returned, the department paste and affix the Show Cause Notice at the same address - The Show Cause Notice was not issued to the appellant and also that the order has been passed exparte. - Clear violation of principles of natural justice is established - the demand cannot sustain and requires to be set aside - AT
Service of SCN - SCN not sent at proper address - The department was fully aware that the appellant is not residing and not available in the address - After the Show Cause Notice was returned, the department paste and affix the Show Cause Notice at the same address - The Show Cause Notice was not issued to the appellant and also that the order has been passed exparte. - Clear violation of principles of natural justice is established - the demand cannot sustain and requires to be set aside - AT
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