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...
Order set aside for violation of principles of natural justice by denying petitioner opportunity of oral hearing before passing adverse assessment order raising excess demand. Assessing Authority mandated to afford such opportunity irrespective of petitioner's choice. In assessment orders creating heavy civil liability, granting minimal hearing opportunity essential. Matter remitted to issue fresh notice to petitioner within two weeks for hearing before passing fresh order.
Order set aside for violation of principles of natural justice by denying petitioner opportunity of oral hearing before passing adverse assessment order raising excess demand. Assessing Authority mandated to afford such opportunity irrespective of petitioner's choice. In assessment orders creating heavy civil liability, granting minimal hearing opportunity essential. Matter remitted to issue fresh notice to petitioner within two weeks for hearing before passing fresh order.
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