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 dismissed writ petition challenging assessment order under s.143(3) r.w.s. 144B, finding no clear breach of natural justice principles to warrant bypassing alternate remedies. Show-cause notice adequately informed petitioner about unreliable sales figures and proposed assessment methodology. Final assessment order did not materially deviate from notice parameters. Petitioner's conditional request for video conferencing hearing was not mandatory since AO required no clarifications. Court held statutory appeals must be exhausted first as no patent violation of natural justice was established to justify extraordinary writ jurisdiction.
HC dismissed writ petition challenging assessment order under s.143(3) r.w.s. 144B, finding no clear breach of natural justice principles to warrant bypassing alternate remedies. Show-cause notice adequately informed petitioner about unreliable sales figures and proposed assessment methodology. Final assessment order did not materially deviate from notice parameters. Petitioner's conditional request for video conferencing hearing was not mandatory since AO required no clarifications. Court held statutory appeals must be exhausted first as no patent violation of natural justice was established to justify extraordinary writ jurisdiction.
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