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...
The High Court set aside an assessment order due to lack of reasonable opportunity for the petitioner to contest the tax demand on merits. The show cause notice and other communications were uploaded on the GST portal's "View Additional Notices and Orders" tab but not communicated through other modes, violating principles of natural justice. The court ordered the petitioner to remit 10% of the disputed tax demand within two weeks and permitted submission of a reply to the show cause notice, providing an opportunity to contest the demand. The petition was disposed of on this condition.
The High Court set aside an assessment order due to lack of reasonable opportunity for the petitioner to contest the tax demand on merits. The show cause notice and other communications were uploaded on the GST portal's "View Additional Notices and Orders" tab but not communicated through other modes, violating principles of natural justice. The court ordered the petitioner to remit 10% of the disputed tax demand within two weeks and permitted submission of a reply to the show cause notice, providing an opportunity to contest the demand. The petition was disposed of on this condition.
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