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 the impugned assessment order due to improper service of show cause notices through GST portal instead of tender or RPAD, violating natural justice principles. While disposing of the petition, court directed petitioner to deposit 25% of disputed taxes within four weeks, with adjustments for any prior recoveries or pre-deposits. Assessing authority must calculate and intimate remaining balance within one week, which petitioner must pay within three weeks of intimation. The impugned order dated 20.08.2024 was set aside, emphasizing procedural compliance in tax assessment notices.
HC set aside the impugned assessment order due to improper service of show cause notices through GST portal instead of tender or RPAD, violating natural justice principles. While disposing of the petition, court directed petitioner to deposit 25% of disputed taxes within four weeks, with adjustments for any prior recoveries or pre-deposits. Assessing authority must calculate and intimate remaining balance within one week, which petitioner must pay within three weeks of intimation. The impugned order dated 20.08.2024 was set aside, emphasizing procedural compliance in tax assessment notices.
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