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...
Levy of GST on un-denatured Extra Neutral Alcohol supplied by the petitioner - The court observed that the show cause notice called upon the petitioner to submit a written explanation within 30 days, along with the opportunity for a personal hearing. However, the petitioner failed to provide any explanation or seek a hearing. The court emphasized that the petitioner's failure to provide a written explanation in response to the notice rendered the petition not maintainable. It underscored the importance of availing the opportunity to present a defense before challenging such notices in court.
Levy of GST on un-denatured Extra Neutral Alcohol supplied by the petitioner - The court observed that the show cause notice called upon the petitioner to submit a written explanation within 30 days, along with the opportunity for a personal hearing. However, the petitioner failed to provide any explanation or seek a hearing. The court emphasized that the petitioner's failure to provide a written explanation in response to the notice rendered the petition not maintainable. It underscored the importance of availing the opportunity to present a defense before challenging such notices in court.
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