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 quashed the impugned summary order passed without issuing Form DRC-01 show cause notice to the petitioner, violating principles of natural justice. The matter was remanded to the respondent authorities for de novo adjudication after providing an opportunity of hearing to the petitioner. Fresh order to be passed within 12 weeks in accordance with law. The petition was disposed of by way of remand.
The High Court quashed the impugned summary order passed without issuing Form DRC-01 show cause notice to the petitioner, violating principles of natural justice. The matter was remanded to the respondent authorities for de novo adjudication after providing an opportunity of hearing to the petitioner. Fresh order to be passed within 12 weeks in accordance with law. The petition was disposed of by way of remand.
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