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...
Challenge to the cancellation of registration and rejection of an application for revocation of cancellation. The key points are: The show cause notice (SCN) did not identify the issuing authority, violating principles of natural justice as the petitioner could not adequately respond. The SCN lacked details about the alleged fraud, misstatement, or suppression. The order canceling registration and rejecting the revocation application was vague and non-speaking, without providing reasons. Consequently, the High Court set aside the impugned order dated 2nd January 2024 and disposed of the writ petition.
Challenge to the cancellation of registration and rejection of an application for revocation of cancellation. The key points are: The show cause notice (SCN) did not identify the issuing authority, violating principles of natural justice as the petitioner could not adequately respond. The SCN lacked details about the alleged fraud, misstatement, or suppression. The order canceling registration and rejecting the revocation application was vague and non-speaking, without providing reasons. Consequently, the High Court set aside the impugned order dated 2nd January 2024 and disposed of the writ petition.
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