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...
Violation of principles of natural justice due to absence of appellant's counsel during proceedings. High Court noted counsel's absence on certain dates, but matter reserved on 29.04.2024 without hearing. Unexpectedly relisted on 18.07.2024 without counsel's presence. Impugned order cancelling bail passed on 25.07.2024 without hearing appellant's counsel who had obtained bail from trial court. Impugned order set aside, matter remanded to High Court to reconsider respondent's application for cancellation of bail after hearing both sides. Appellant to ensure counsel's presence, avoid delay.
Violation of principles of natural justice due to absence of appellant's counsel during proceedings. High Court noted counsel's absence on certain dates, but matter reserved on 29.04.2024 without hearing. Unexpectedly relisted on 18.07.2024 without counsel's presence. Impugned order cancelling bail passed on 25.07.2024 without hearing appellant's counsel who had obtained bail from trial court. Impugned order set aside, matter remanded to High Court to reconsider respondent's application for cancellation of bail after hearing both sides. Appellant to ensure counsel's presence, avoid delay.
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