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 dismissed the appeal challenging the order issued by the National Faceless Appeal Centre (NFAC) u/s 250 of the Income Tax Act. The court held that the appellant was afforded sufficient opportunity to produce supporting documents, but repeatedly sought adjournments without producing any documents, indicating a delay tactic. The notices issued u/s 250 satisfied the statutory requirements, explicitly conveying the purpose of the hearing. The appellant's contention of violation of natural justice principles was rejected, as a person who fails to avail the opportunity to make submissions and produce documents cannot complain about such violation. However, the High Court modified the single judge's direction requiring the appellant to remit 20% of the disputed tax as a pre-condition for filing a stay petition before the Appellate Tribunal.
The High Court dismissed the appeal challenging the order issued by the National Faceless Appeal Centre (NFAC) u/s 250 of the Income Tax Act. The court held that the appellant was afforded sufficient opportunity to produce supporting documents, but repeatedly sought adjournments without producing any documents, indicating a delay tactic. The notices issued u/s 250 satisfied the statutory requirements, explicitly conveying the purpose of the hearing. The appellant's contention of violation of natural justice principles was rejected, as a person who fails to avail the opportunity to make submissions and produce documents cannot complain about such violation. However, the High Court modified the single judge's direction requiring the appellant to remit 20% of the disputed tax as a pre-condition for filing a stay petition before the Appellate Tribunal.
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