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...
Principles of natural justice violated due to lack of reasonable opportunity to contest tax demand. Petitioner cited ongoing tax audit and father's illness for seeking adjournment, but failed to submit substantive reply from September 2023 to February 2024 despite sufficient time. Considering health records submitted, petitioner granted opportunity to contest demand by remitting 10% of disputed tax within three weeks. Matter remanded for reconsideration after compliance.
Principles of natural justice violated due to lack of reasonable opportunity to contest tax demand. Petitioner cited ongoing tax audit and father's illness for seeking adjournment, but failed to submit substantive reply from September 2023 to February 2024 despite sufficient time. Considering health records submitted, petitioner granted opportunity to contest demand by remitting 10% of disputed tax within three weeks. Matter remanded for reconsideration after compliance.
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