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 HC held that issuing a consolidated show cause notice for multiple assessment years from 2019 to 2023-24 was erroneous. It relied on precedents from Karnataka and Madras HCs which held that separate notices should be issued for each year u/s 73 of the GST Act. The HC granted an extension till 21.11.2024 for filing a reply to the 1622-page notice and excluded the corresponding period for passing orders to offset the delay.
The HC held that issuing a consolidated show cause notice for multiple assessment years from 2019 to 2023-24 was erroneous. It relied on precedents from Karnataka and Madras HCs which held that separate notices should be issued for each year u/s 73 of the GST Act. The HC granted an extension till 21.11.2024 for filing a reply to the 1622-page notice and excluded the corresponding period for passing orders to offset the delay.
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