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 - breach of principles of natural justice - During an inspection, the petitioner addressed discrepancies pointed out by the authorities but failed to respond to subsequent notices and participate in assessment proceedings. Despite this, the High Court finds it necessary to interfere with the assessment order, subjecting the petitioner to certain conditions. These include remitting a specified sum towards the disputed tax demand and submitting a reply to the show cause notice within a stipulated period. The Court directs the assessing officer to issue a fresh assessment order within two months, adhering to prescribed procedures.
Validity of assessment order - breach of principles of natural justice - During an inspection, the petitioner addressed discrepancies pointed out by the authorities but failed to respond to subsequent notices and participate in assessment proceedings. Despite this, the High Court finds it necessary to interfere with the assessment order, subjecting the petitioner to certain conditions. These include remitting a specified sum towards the disputed tax demand and submitting a reply to the show cause notice within a stipulated period. The Court directs the assessing officer to issue a fresh assessment order within two months, adhering to prescribed procedures.
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