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 cancelling petitioner's registration violated principles of natural justice as it was passed mechanically without application of mind and without assigning reasons. Appeal against cancellation dismissed on ground of delay. Reasons are essential for judicial and administrative orders. Doctrine of merger inapplicable due to circumstances. Referring to precedent, order without reasons fails Article 14 test of reasonableness. Impugned cancellation order quashed for lack of reasons, allowing the petition.
Order cancelling petitioner's registration violated principles of natural justice as it was passed mechanically without application of mind and without assigning reasons. Appeal against cancellation dismissed on ground of delay. Reasons are essential for judicial and administrative orders. Doctrine of merger inapplicable due to circumstances. Referring to precedent, order without reasons fails Article 14 test of reasonableness. Impugned cancellation order quashed for lack of reasons, allowing the petition.
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