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 and bank attachment order - Input Tax Credit (ITC) availed of by the petitioner was reversed on the ground that three suppliers had issued credit notes to the petitioner - The High court quashed the impugned assessment order dated 11.08.2023 and remands the matter for reconsideration by the first respondent. - The petitioner is granted the opportunity to reply to the show cause notice within two weeks, and the first respondent is directed to provide a reasonable opportunity for a fresh assessment order within two months thereafter.
Validity of assessment order and bank attachment order - Input Tax Credit (ITC) availed of by the petitioner was reversed on the ground that three suppliers had issued credit notes to the petitioner - The High court quashed the impugned assessment order dated 11.08.2023 and remands the matter for reconsideration by the first respondent. - The petitioner is granted the opportunity to reply to the show cause notice within two weeks, and the first respondent is directed to provide a reasonable opportunity for a fresh assessment order within two months thereafter.
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