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 petition raised issues regarding the maintainability of the appeal u/s 107 of the UPGST Act, 2017, violation of Section 75(4) of the Act, and denial of opportunity for personal hearing, amounting to a violation of principles of natural justice. The Court held that the impugned order was passed without fixing any date or issuing further notice for another hearing date, rendering it an ex parte order. Relying on a previous judgment, the Court remitted the matter to the Deputy Commissioner to pass a fresh order after affording due opportunity of hearing to the petitioner, thereby disposing of the petition by way of remand.
The petition raised issues regarding the maintainability of the appeal u/s 107 of the UPGST Act, 2017, violation of Section 75(4) of the Act, and denial of opportunity for personal hearing, amounting to a violation of principles of natural justice. The Court held that the impugned order was passed without fixing any date or issuing further notice for another hearing date, rendering it an ex parte order. Relying on a previous judgment, the Court remitted the matter to the Deputy Commissioner to pass a fresh order after affording due opportunity of hearing to the petitioner, thereby disposing of the petition by way of remand.
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