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 partly allowed the challenge to the assessment order passed by the second respondent for the Assessment Year 2017-2018. The Court quashed the impugned Assessment Order for violating principles of natural justice and lack of jurisdiction. It remitted the case to the respondents to pass a fresh order, subject to conditions: the petitioner shall deposit 10% of the disputed tax of Rs. 31,56,386/- within six weeks, and file a detailed reply to the quashed Assessment Order, treated as an addendum to the Show Cause Notice dated 11.02.2021, within thirty days. The petition was disposed of accordingly.
The High Court partly allowed the challenge to the assessment order passed by the second respondent for the Assessment Year 2017-2018. The Court quashed the impugned Assessment Order for violating principles of natural justice and lack of jurisdiction. It remitted the case to the respondents to pass a fresh order, subject to conditions: the petitioner shall deposit 10% of the disputed tax of Rs. 31,56,386/- within six weeks, and file a detailed reply to the quashed Assessment Order, treated as an addendum to the Show Cause Notice dated 11.02.2021, within thirty days. The petition was disposed of accordingly.
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