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...
ITAT set aside CIT(A)'s ex-parte order for failing to comply with Section 250(6) requirements. The CIT(A) neither provided proper hearing opportunity nor issued a reasoned order addressing appeal grounds. Following judicial precedents establishing that appeals cannot be dismissed for non-prosecution and require speaking orders with substantive findings, ITAT remanded the matter back to CIT(A). The tribunal directed CIT(A) to pass a fresh speaking order after giving the assessee reasonable opportunity of being heard, considering submitted documents, and adjudicating all grounds of appeal in accordance with law and Rule 46A of Income Tax Rules. Appeal allowed for statistical purposes.
ITAT set aside CIT(A)'s ex-parte order for failing to comply with Section 250(6) requirements. The CIT(A) neither provided proper hearing opportunity nor issued a reasoned order addressing appeal grounds. Following judicial precedents establishing that appeals cannot be dismissed for non-prosecution and require speaking orders with substantive findings, ITAT remanded the matter back to CIT(A). The tribunal directed CIT(A) to pass a fresh speaking order after giving the assessee reasonable opportunity of being heard, considering submitted documents, and adjudicating all grounds of appeal in accordance with law and Rule 46A of Income Tax Rules. Appeal allowed for statistical purposes.
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