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...
Cancellation of grant of authorised operations of warehousing service activities - Section 16 of the SEZ Act, 2005 - The High Court found that the impugned letter, which suspended D.T.A. clearance, lacked legal basis. It observed that the respondents failed to cite any provision of the SEZ Act to justify their actions. - Consequently, the Court quashed and set aside the impugned order dated 01st November, 2023. It directed the respondents to proceed with the adjudication of the show-cause notice dated 08th January, 2024, in accordance with the law.
Cancellation of grant of authorised operations of warehousing service activities - Section 16 of the SEZ Act, 2005 - The High Court found that the impugned letter, which suspended D.T.A. clearance, lacked legal basis. It observed that the respondents failed to cite any provision of the SEZ Act to justify their actions. - Consequently, the Court quashed and set aside the impugned order dated 01st November, 2023. It directed the respondents to proceed with the adjudication of the show-cause notice dated 08th January, 2024, in accordance with the law.
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