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...
Order quashed due to violation of natural justice principles by not granting proper opportunity for personal hearing. Excess input tax credit availed on inputs subject to reverse charge mechanism and non-reversal of credit on reversed credit notes. Matter remanded for reconsideration after granting personal hearing to petitioner within stipulated timeframe. Final orders to be passed in accordance with law after following due process.
Order quashed due to violation of natural justice principles by not granting proper opportunity for personal hearing. Excess input tax credit availed on inputs subject to reverse charge mechanism and non-reversal of credit on reversed credit notes. Matter remanded for reconsideration after granting personal hearing to petitioner within stipulated timeframe. Final orders to be passed in accordance with law after following due process.
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