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...
The High Court reviewed an assessment order challenged for being unreasoned. The Court found that the order lacked proper reasoning as it confirmed the tax proposal without explanation, rendering it unsustainable. The order was set aside, and the case remanded for reconsideration. The respondent was instructed to grant the taxpayer a fair opportunity, including a personal hearing, and issue a new order within three months. Consequently, the bank attachment linked to the assessment order was lifted. The petition was disposed of through remand.
The High Court reviewed an assessment order challenged for being unreasoned. The Court found that the order lacked proper reasoning as it confirmed the tax proposal without explanation, rendering it unsustainable. The order was set aside, and the case remanded for reconsideration. The respondent was instructed to grant the taxpayer a fair opportunity, including a personal hearing, and issue a new order within three months. Consequently, the bank attachment linked to the assessment order was lifted. The petition was disposed of through remand.
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