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 quashed tax demand order under GST Act due to procedural irregularities in notice service. Petitioner claimed no awareness of notices or orders, preventing timely response within limitation period. Court found merit in petitioner's contention that order was not visible under system's "view notices and orders" tab, constituting violation of natural justice principles. Given that disputed amount was already deposited with State Government, HC directed treating impugned order as final notice, granting petitioner two weeks to submit written reply instead of relegating to statutory remedy. Matter resolved considering procedural fairness and existing tax deposit.
HC quashed tax demand order under GST Act due to procedural irregularities in notice service. Petitioner claimed no awareness of notices or orders, preventing timely response within limitation period. Court found merit in petitioner's contention that order was not visible under system's "view notices and orders" tab, constituting violation of natural justice principles. Given that disputed amount was already deposited with State Government, HC directed treating impugned order as final notice, granting petitioner two weeks to submit written reply instead of relegating to statutory remedy. Matter resolved considering procedural fairness and existing tax deposit.
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