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...
Impugned assessment order violated principles of natural justice as petitioner was not provided further opportunity after show cause notice nine months prior. Petitioner's reply did not address show cause notice. Tax demand confirmed without hearing petitioner. Order set aside, matter remanded for reconsideration on condition petitioner remits 10% of disputed tax demand within two weeks and submits reply to show cause notice. Petition disposed of.
Impugned assessment order violated principles of natural justice as petitioner was not provided further opportunity after show cause notice nine months prior. Petitioner's reply did not address show cause notice. Tax demand confirmed without hearing petitioner. Order set aside, matter remanded for reconsideration on condition petitioner remits 10% of disputed tax demand within two weeks and submits reply to show cause notice. Petition disposed of.
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