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...
Rejection of the application under SVLDRS due to an ongoing investigation and non-quantification of duty as of the cut-off date, June 30, 2019. - The court observed that, summary rejection of an application without affording an opportunity of being heard would fall foul of the principles of natural justice. - The High Court directed the respondents (Revenue) to consider the declaration of the petitioner in terms of the Scheme as a valid declaration under the category of “investigation, enquiry and audit” and grant the consequential reliefs to the petitioner.
Rejection of the application under SVLDRS due to an ongoing investigation and non-quantification of duty as of the cut-off date, June 30, 2019. - The court observed that, summary rejection of an application without affording an opportunity of being heard would fall foul of the principles of natural justice. - The High Court directed the respondents (Revenue) to consider the declaration of the petitioner in terms of the Scheme as a valid declaration under the category of “investigation, enquiry and audit” and grant the consequential reliefs to the petitioner.
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