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...
Tax authority rejected rectification application filed by taxpayer for zero-rated supply citing violation of principles of natural justice. Court examined impugned order, found taxpayer's reply and documents were considered for most defects except two. For those two defects, court set aside impugned order subject to taxpayer remitting 20% of disputed tax demand and re-submitting relevant documents within 15 days. Tax authority directed to provide reasonable opportunity including personal hearing to taxpayer and pass fresh order within 3 months after receiving taxpayer's reply. Petition disposed.
Tax authority rejected rectification application filed by taxpayer for zero-rated supply citing violation of principles of natural justice. Court examined impugned order, found taxpayer's reply and documents were considered for most defects except two. For those two defects, court set aside impugned order subject to taxpayer remitting 20% of disputed tax demand and re-submitting relevant documents within 15 days. Tax authority directed to provide reasonable opportunity including personal hearing to taxpayer and pass fresh order within 3 months after receiving taxpayer's reply. Petition disposed.
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