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 dated 08.04.2024 for violation of principles of natural justice due to non-service of show cause notices and assessment order. The case involved availment of input tax credit on alleged supplies from bill traders based on bogus invoices without actual goods involvement. Considering the petitioner had remitted the disputed taxes, the Court granted them a final opportunity to file objections within two weeks, treating the impugned order as a show cause notice. The petition was disposed of accordingly.
The High Court set aside the impugned order dated 08.04.2024 for violation of principles of natural justice due to non-service of show cause notices and assessment order. The case involved availment of input tax credit on alleged supplies from bill traders based on bogus invoices without actual goods involvement. Considering the petitioner had remitted the disputed taxes, the Court granted them a final opportunity to file objections within two weeks, treating the impugned order as a show cause notice. The petition was disposed of accordingly.
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