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 petition challenging the validity of the order of reassessment. It held that sufficient opportunities were granted to the petitioner by serving notices physically and through email. The petitioner had responded to the notice u/s 148A(b) of the Act and even sought further time for filing an additional response. However, no objection was subsequently filed, and the Income Tax Officer passed appropriate orders in accordance with the law. The petitioner had provided an email address for communication and had submitted a response through that email ID. Hence, notices issued to that email ID cannot be considered irregular. The petitioner was aware of the proceedings but failed to avail the opportunity granted. The contention of unawareness of the technological mode of serving notices was rejected by the Court. The Court found no merit in the contention regarding violation of principles of natural justice.
The High Court dismissed the petition challenging the validity of the order of reassessment. It held that sufficient opportunities were granted to the petitioner by serving notices physically and through email. The petitioner had responded to the notice u/s 148A(b) of the Act and even sought further time for filing an additional response. However, no objection was subsequently filed, and the Income Tax Officer passed appropriate orders in accordance with the law. The petitioner had provided an email address for communication and had submitted a response through that email ID. Hence, notices issued to that email ID cannot be considered irregular. The petitioner was aware of the proceedings but failed to avail the opportunity granted. The contention of unawareness of the technological mode of serving notices was rejected by the Court. The Court found no merit in the contention regarding violation of principles of natural justice.
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