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...
Notices issued to a deceased person and subsequent assessment orders passed based on such notices are void ab initio, violating principles of natural justice. The High Court held that issuing notices and passing orders against a deceased assessee, without knowledge of their demise, renders the proceedings ex parte and suffers from violation of natural justice. Consequently, the impugned orders and consequential recovery proceedings were set aside, and the matter was remitted for fresh consideration by the authority.
Notices issued to a deceased person and subsequent assessment orders passed based on such notices are void ab initio, violating principles of natural justice. The High Court held that issuing notices and passing orders against a deceased assessee, without knowledge of their demise, renders the proceedings ex parte and suffers from violation of natural justice. Consequently, the impugned orders and consequential recovery proceedings were set aside, and the matter was remitted for fresh consideration by the authority.
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