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 upheld the validity of a show-cause notice (SCN) regarding short payment of tax on commission income of Rs. 16,56,267/-. The authority correctly determined that commission received from M/s. Jembo Cable could not qualify as an exempted service. Court emphasized that SCN represents a preliminary procedural step, ensuring principles of natural justice by allowing petitioner to present evidence and submissions during adjudication. The adjudicating authority must consider all submissions before passing final order. Court found SCN lawful as integral part of tax adjudication process, particularly concerning determination of claimed exemption applicability. Application disposed of accordingly.
HC upheld the validity of a show-cause notice (SCN) regarding short payment of tax on commission income of Rs. 16,56,267/-. The authority correctly determined that commission received from M/s. Jembo Cable could not qualify as an exempted service. Court emphasized that SCN represents a preliminary procedural step, ensuring principles of natural justice by allowing petitioner to present evidence and submissions during adjudication. The adjudicating authority must consider all submissions before passing final order. Court found SCN lawful as integral part of tax adjudication process, particularly concerning determination of claimed exemption applicability. Application disposed of accordingly.
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