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...
Violation of principles of natural justice - Mode of Communication - petitioner submits that in most of the cases, the assessees are not aware of the show cause notices and assessment orders due to lack of communication through post - The Court recognized the petitioner's argument regarding the lack of awareness among traders regarding electronic communications. It emphasized the importance of providing adequate opportunity to taxpayers, suggesting that notices should also be issued through postal services and in regional languages to facilitate better understanding and response. - The Court noted the petitioner's assertion regarding the Department's failure to adhere to prescribed procedures. - It emphasized the importance of fair procedures and providing sufficient opportunity to taxpayers before passing adverse orders.
Violation of principles of natural justice - Mode of Communication - petitioner submits that in most of the cases, the assessees are not aware of the show cause notices and assessment orders due to lack of communication through post - The Court recognized the petitioner's argument regarding the lack of awareness among traders regarding electronic communications. It emphasized the importance of providing adequate opportunity to taxpayers, suggesting that notices should also be issued through postal services and in regional languages to facilitate better understanding and response. - The Court noted the petitioner's assertion regarding the Department's failure to adhere to prescribed procedures. - It emphasized the importance of fair procedures and providing sufficient opportunity to taxpayers before passing adverse orders.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4800
Join Channel
TaxTMI 
