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...
Violation of principles of natural justice - petitioner unable to contest tax demand as consultant failed to inform about proceedings - examining impugned order, tax proposal confirmed due to non-reply to show cause notice - proposal related to comparison between inward supply from GSTR 2A and outward supply - petitioner opted for composition levy, filed GSTR 4 quarterly returns - in circumstances, interest of justice warrants reconsideration by putting petitioner on terms - impugned order set aside on condition petitioner remits 10% of disputed tax demand within two weeks - petition disposed off.
Violation of principles of natural justice - petitioner unable to contest tax demand as consultant failed to inform about proceedings - examining impugned order, tax proposal confirmed due to non-reply to show cause notice - proposal related to comparison between inward supply from GSTR 2A and outward supply - petitioner opted for composition levy, filed GSTR 4 quarterly returns - in circumstances, interest of justice warrants reconsideration by putting petitioner on terms - impugned order set aside on condition petitioner remits 10% of disputed tax demand within two weeks - petition disposed off.
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