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 HC quashed the show cause notice pending adjudication for over 15 years due to inordinate and unexplained delay by the respondent. The respondent's affidavit failed to justify the delay satisfactorily. The SC order cited does not mandate excusing gross, unjustifiable, and inordinate delays in adjudicating show cause notices without reasonable explanation. Consequently, the HC restrained the respondents from further proceedings based on the impugned show cause notice.
The HC quashed the show cause notice pending adjudication for over 15 years due to inordinate and unexplained delay by the respondent. The respondent's affidavit failed to justify the delay satisfactorily. The SC order cited does not mandate excusing gross, unjustifiable, and inordinate delays in adjudicating show cause notices without reasonable explanation. Consequently, the HC restrained the respondents from further proceedings based on the impugned show cause notice.
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