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 allowed the petition by way of remand due to violation of principles of natural justice by the 4th Respondent. While the Petitioner's reply to the show-cause notice was unclear, the 4th Respondent failed to consider the Petitioner's contention that a petition was filed challenging the show-cause notice. The impugned order lacked reasons for finding the reply unsatisfactory, amounting to a breach of natural justice. Consequently, the matter was remanded without requiring the Petitioner to exhaust alternate remedies.
The High Court allowed the petition by way of remand due to violation of principles of natural justice by the 4th Respondent. While the Petitioner's reply to the show-cause notice was unclear, the 4th Respondent failed to consider the Petitioner's contention that a petition was filed challenging the show-cause notice. The impugned order lacked reasons for finding the reply unsatisfactory, amounting to a breach of natural justice. Consequently, the matter was remanded without requiring the Petitioner to exhaust alternate remedies.
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