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 o Ex parte scrutiny assessment order u/s 143(3) r.w.s. 144B - The court highlighted the importance of oral hearing in assessment proceedings, stating that it is essential for an effective discussion and a reasoned conclusion by the Assessing Officer. It was emphasized that assessment orders should be passed after giving the assessee an opportunity to present their case, and oral hearing remains a near-mandatory requirement to ensure a just and proper order.
Validity of o Ex parte scrutiny assessment order u/s 143(3) r.w.s. 144B - The court highlighted the importance of oral hearing in assessment proceedings, stating that it is essential for an effective discussion and a reasoned conclusion by the Assessing Officer. It was emphasized that assessment orders should be passed after giving the assessee an opportunity to present their case, and oral hearing remains a near-mandatory requirement to ensure a just and proper order.
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