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 found no statutory requirement mandating obtaining a statement as a prerequisite for issuing show cause notice u/s 122(1A) of CGST Act, 2017. Petitioner granted 4 weeks to file objections to the notice from receipt of order. Respondents directed to consider objections according to law, providing reasonable hearing opportunity before proceeding with assessment/adjudication. Court explicitly noted no views expressed on merits. Petition disposed of with directions for procedural compliance while preserving petitioner's right to present defense during adjudication process.
HC found no statutory requirement mandating obtaining a statement as a prerequisite for issuing show cause notice u/s 122(1A) of CGST Act, 2017. Petitioner granted 4 weeks to file objections to the notice from receipt of order. Respondents directed to consider objections according to law, providing reasonable hearing opportunity before proceeding with assessment/adjudication. Court explicitly noted no views expressed on merits. Petition disposed of with directions for procedural compliance while preserving petitioner's right to present defense during adjudication process.
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