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 u/s 74 - The order passed based on a report from the Irrigation and Waterways Directorate, Govt. of West Bengal, regarding the disclosure of turnover of outward taxable supply during a specific tax period. - The High Court noted that the failure to provide the report to the petitioner violated principles of natural justice, as the petitioner was not given the opportunity to respond to the content of the report that formed the basis of the adjudication. - Matter restored back.
Validity of assessment order u/s 74 - The order passed based on a report from the Irrigation and Waterways Directorate, Govt. of West Bengal, regarding the disclosure of turnover of outward taxable supply during a specific tax period. - The High Court noted that the failure to provide the report to the petitioner violated principles of natural justice, as the petitioner was not given the opportunity to respond to the content of the report that formed the basis of the adjudication. - Matter restored back.
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