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...
Petitioner failed to authorize representative for GST matters after registration under GST regime, resulting in show cause notice being served on auditor without petitioner's knowledge. Petitioner unable to respond or attend hearing due to lack of notice. Order passed without granting opportunity of personal hearing, violating natural justice principles. High Court set aside original order, remanded matter for fresh consideration by department, subject to petitioner paying 7.5% of disputed tax within four weeks. Petition allowed by way of remand due to department's fault in denying petitioner opportunity to respond.
Petitioner failed to authorize representative for GST matters after registration under GST regime, resulting in show cause notice being served on auditor without petitioner's knowledge. Petitioner unable to respond or attend hearing due to lack of notice. Order passed without granting opportunity of personal hearing, violating natural justice principles. High Court set aside original order, remanded matter for fresh consideration by department, subject to petitioner paying 7.5% of disputed tax within four weeks. Petition allowed by way of remand due to department's fault in denying petitioner opportunity to respond.
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