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...
Writ petition challenging show cause notice (SCN) and adjudication order attaching petitioner's bank account. SCN not uploaded in "view notices and orders" section of portal, violating principles of natural justice. Court held petitioner entitled to 30 days to respond to SCN u/s 73(8) of Act. Though SCN uploaded in "view additional notices and orders" section, confusion in identifying notices in pre-redesigned portal dashboard. Petitioner permitted to approach appellate authority. Attachment order quashed for lack of opportunity to respond. Petition disposed of.
Writ petition challenging show cause notice (SCN) and adjudication order attaching petitioner's bank account. SCN not uploaded in "view notices and orders" section of portal, violating principles of natural justice. Court held petitioner entitled to 30 days to respond to SCN u/s 73(8) of Act. Though SCN uploaded in "view additional notices and orders" section, confusion in identifying notices in pre-redesigned portal dashboard. Petitioner permitted to approach appellate authority. Attachment order quashed for lack of opportunity to respond. Petition disposed of.
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