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 set aside the impugned tax demand order due to violation of principles of natural justice, as the petitioner was not provided a reasonable opportunity to contest the tax demand on merits. The petitioner was unaware of the proceedings culminating in the order, which related to a mismatch between the petitioner's GSTR 3B returns and the auto-populated GSTR 2A. The court permitted the petitioner to submit a reply to the show cause notice after remitting 10% of the disputed tax demand, in the interest of justice, to contest the tax demand on merits. The petition was disposed of on this condition.
The High Court set aside the impugned tax demand order due to violation of principles of natural justice, as the petitioner was not provided a reasonable opportunity to contest the tax demand on merits. The petitioner was unaware of the proceedings culminating in the order, which related to a mismatch between the petitioner's GSTR 3B returns and the auto-populated GSTR 2A. The court permitted the petitioner to submit a reply to the show cause notice after remitting 10% of the disputed tax demand, in the interest of justice, to contest the tax demand on merits. The petition was disposed of on this condition.
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