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 order of assessment due to violation of principles of natural justice as the show cause notice and the order were not served properly to the petitioner. The petitioner was directed to deposit 25% of the disputed tax within four weeks and submit objections along with supporting documents within four weeks from receipt of the order. The respondent was directed to consider the objections after providing a reasonable opportunity of hearing to the petitioner and pass orders in accordance with law. The writ petition was disposed of.
The High Court set aside the impugned order of assessment due to violation of principles of natural justice as the show cause notice and the order were not served properly to the petitioner. The petitioner was directed to deposit 25% of the disputed tax within four weeks and submit objections along with supporting documents within four weeks from receipt of the order. The respondent was directed to consider the objections after providing a reasonable opportunity of hearing to the petitioner and pass orders in accordance with law. The writ petition was disposed of.
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