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, considering that the petitioner's certain pleas were not taken into account while issuing the notice u/s 74(1) and that the limitation for filing an appeal had been lost, directed that if the petitioner deposits 50% of the demanded amount of Rs. 73,87,225.92, after adjusting any amount already paid within four weeks, the impugned order dated 24.07.2023 shall stand set aside. The respondent would then afford an opportunity of hearing to the petitioner and pass a fresh order, upholding the principles of natural justice.
The High Court, considering that the petitioner's certain pleas were not taken into account while issuing the notice u/s 74(1) and that the limitation for filing an appeal had been lost, directed that if the petitioner deposits 50% of the demanded amount of Rs. 73,87,225.92, after adjusting any amount already paid within four weeks, the impugned order dated 24.07.2023 shall stand set aside. The respondent would then afford an opportunity of hearing to the petitioner and pass a fresh order, upholding the principles of natural justice.
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