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 - reply to the ASTM-10 notice was not taken into consideration - violation of principles of natural justice - Acknowledging the importance of providing the petitioner with an opportunity to contest the tax demand on merits, the High Court decides to set aside the impugned order. However, this is conditional on the petitioner remitting 10% of the disputed tax demand within two weeks and submitting a reply to the show cause notice within the same period.
Validity of assessment order - reply to the ASTM-10 notice was not taken into consideration - violation of principles of natural justice - Acknowledging the importance of providing the petitioner with an opportunity to contest the tax demand on merits, the High Court decides to set aside the impugned order. However, this is conditional on the petitioner remitting 10% of the disputed tax demand within two weeks and submitting a reply to the show cause notice within the same period.
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