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...
HC allowed petition - Assessing officer's order violated principles of natural justice by denying opportunity to petitioner to present defense - Failure to serve show cause notice rendered proceedings flawed - Appeal remedy denied due to delay caused by lack of knowledge of order - Procedural requirements mandatory, non-compliance invalidates actions - Fair opportunity must be given to all parties - Appeal timelines to consider actual knowledge of orders - Assessing officer's order treated as show cause notice to enable petitioner to file objections.
HC allowed petition - Assessing officer's order violated principles of natural justice by denying opportunity to petitioner to present defense - Failure to serve show cause notice rendered proceedings flawed - Appeal remedy denied due to delay caused by lack of knowledge of order - Procedural requirements mandatory, non-compliance invalidates actions - Fair opportunity must be given to all parties - Appeal timelines to consider actual knowledge of orders - Assessing officer's order treated as show cause notice to enable petitioner to file objections.
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