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...
A reading of Section 169 of the Act makes it clear that any decision, order, summons, notice or other communication under the Act or Rules may be served on the assessee by making it available on the common portal. This statutory provision has to be read along with Section 146, which means that once a common portal is notified for the Act's purposes, actions like registration, tax payment, returns filing, and communication of notices, orders, etc., can be effected through the notified portal. The appellant's principal contention that the assessment order communicated through the notified portal was not known due to belated access was rejected. The appeal was dismissed.
A reading of Section 169 of the Act makes it clear that any decision, order, summons, notice or other communication under the Act or Rules may be served on the assessee by making it available on the common portal. This statutory provision has to be read along with Section 146, which means that once a common portal is notified for the Act's purposes, actions like registration, tax payment, returns filing, and communication of notices, orders, etc., can be effected through the notified portal. The appellant's principal contention that the assessment order communicated through the notified portal was not known due to belated access was rejected. The appeal was dismissed.
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