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 Show cause notice - The case pertains to a dealer of woven fabrics and readymade garments challenging a tax demand order due to allegedly insufficient opportunity to contest. Despite delay in response to a show cause notice, subsequent communication and evidence submission by the petitioner suggest efforts to refute discrepancies and comply with requirements. The Government maintains adherence to procedural fairness but acknowledges the petitioner's subsequent explanations for discrepancies. The High Court intervenes, quashing the order subject to conditions ensuring procedural fairness and opportunity for the petitioner to address the tax demand.
Validity Of Show cause notice - The case pertains to a dealer of woven fabrics and readymade garments challenging a tax demand order due to allegedly insufficient opportunity to contest. Despite delay in response to a show cause notice, subsequent communication and evidence submission by the petitioner suggest efforts to refute discrepancies and comply with requirements. The Government maintains adherence to procedural fairness but acknowledges the petitioner's subsequent explanations for discrepancies. The High Court intervenes, quashing the order subject to conditions ensuring procedural fairness and opportunity for the petitioner to address the tax demand.
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