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 quashed the show cause notices and orders issued by the revenue authorities due to inordinate delay ranging from 9 to 20 years in adjudicating the notices, without any justifiable reason. The Court relied on its previous decisions and the Bombay High Court's judgment in Coventry Estates Pvt. Ltd. case, holding that such substantial delay nullifies the noticee's rights and causes irreparable prejudice. Consequently, the show cause notices and orders were quashed and set aside on the ground of non-justification for the delay in adjudication.
The High Court quashed the show cause notices and orders issued by the revenue authorities due to inordinate delay ranging from 9 to 20 years in adjudicating the notices, without any justifiable reason. The Court relied on its previous decisions and the Bombay High Court's judgment in Coventry Estates Pvt. Ltd. case, holding that such substantial delay nullifies the noticee's rights and causes irreparable prejudice. Consequently, the show cause notices and orders were quashed and set aside on the ground of non-justification for the delay in adjudication.
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