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...
Denial of specific request for personal hearing - The High Court noted that the petitioner had indeed expressed a legitimate difficulty in availing the opportunity for a personal hearing through video conference due to technical issues with the web portal. Referring to a previous judgment, the Court emphasized that the mere failure to click on the request button should not preclude the petitioner from being granted a personal hearing, especially when the petitioner had explicitly requested it in written submissions. - Consequently, the Court set aside the impugned assessment order and directed that the assessment be framed after affording the petitioner a reasonable opportunity for a personal hearing through video conference within a specified timeframe.
Denial of specific request for personal hearing - The High Court noted that the petitioner had indeed expressed a legitimate difficulty in availing the opportunity for a personal hearing through video conference due to technical issues with the web portal. Referring to a previous judgment, the Court emphasized that the mere failure to click on the request button should not preclude the petitioner from being granted a personal hearing, especially when the petitioner had explicitly requested it in written submissions. - Consequently, the Court set aside the impugned assessment order and directed that the assessment be framed after affording the petitioner a reasonable opportunity for a personal hearing through video conference within a specified timeframe.
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