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 set aside assessment order due to violation of natural justice principles, specifically addressing non-speaking order deficiency in tax proceedings involving output tax underdeclaration and irregular input tax credit claims. Issues included ITC reversals for non-business transactions, exempted supplies, and credits claimed from cancelled dealers and defaulters. Court permitted revenue authorities to conduct fresh assessment following due process, mandating reasonable opportunity of hearing to the assessee. Matter remanded for de novo proceedings in accordance with law, emphasizing procedural fairness and proper reasoned order requirements.
HC set aside assessment order due to violation of natural justice principles, specifically addressing non-speaking order deficiency in tax proceedings involving output tax underdeclaration and irregular input tax credit claims. Issues included ITC reversals for non-business transactions, exempted supplies, and credits claimed from cancelled dealers and defaulters. Court permitted revenue authorities to conduct fresh assessment following due process, mandating reasonable opportunity of hearing to the assessee. Matter remanded for de novo proceedings in accordance with law, emphasizing procedural fairness and proper reasoned order requirements.
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