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 set aside the non-speaking order of the respondent and remitted the matter back for fresh consideration of the demand in the show cause notice and the petitioner's reply. The respondent failed to consider the petitioner's reconciliation report which showed excess credit of Rs. 1,40,684/- after adjusting IGST, CGST and SGST, violating principles of natural justice. The impugned order did not provide reasons for rejecting the petitioner's explanation. The petition was allowed by way of remand.
The HC set aside the non-speaking order of the respondent and remitted the matter back for fresh consideration of the demand in the show cause notice and the petitioner's reply. The respondent failed to consider the petitioner's reconciliation report which showed excess credit of Rs. 1,40,684/- after adjusting IGST, CGST and SGST, violating principles of natural justice. The impugned order did not provide reasons for rejecting the petitioner's explanation. The petition was allowed by way of remand.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4801
Join Channel
TaxTMI 
