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...
SCN issued for cancellation of registration without detailed reasons. Held: Respondent authorities' approach commendable for complying with natural justice by giving opportunity before cancellation to avoid unnecessary litigation. Authorities directed to adhere to HC's 2022 directives, not issue show-cause notices without detailed reasons or cancel registration without assigning detailed reasons, failing which cost orders against erring officers who breach natural justice despite departmental Standard Operating Procedures. Petition disposed.
SCN issued for cancellation of registration without detailed reasons. Held: Respondent authorities' approach commendable for complying with natural justice by giving opportunity before cancellation to avoid unnecessary litigation. Authorities directed to adhere to HC's 2022 directives, not issue show-cause notices without detailed reasons or cancel registration without assigning detailed reasons, failing which cost orders against erring officers who breach natural justice despite departmental Standard Operating Procedures. Petition disposed.
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