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 and bank attachment notice - no personal hearing provided - The High court notes that the petitioner was not heard before the order issuance and only a summary was uploaded on the GST portal. Consequently, the assessment order and attachment notice are quashed, with the condition that the petitioner pays 10% of the disputed tax demand within two weeks. The assessing officer is directed to provide a reasonable opportunity, including a personal hearing, and issue a fresh assessment order within two months of receiving the payment.
Validity of assessment order and bank attachment notice - no personal hearing provided - The High court notes that the petitioner was not heard before the order issuance and only a summary was uploaded on the GST portal. Consequently, the assessment order and attachment notice are quashed, with the condition that the petitioner pays 10% of the disputed tax demand within two weeks. The assessing officer is directed to provide a reasonable opportunity, including a personal hearing, and issue a fresh assessment order within two months of receiving the payment.
Note: It is a system-generated summary and is for quick reference only.
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