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 examined a challenge to an adjudication order allegedly issued without providing hearing opportunity. Despite claims of natural justice violation, the court found extensive documentation requiring detailed factual analysis. Determining this was not an exceptional case warranting bypass of statutory appeal mechanisms, HC dismissed the appeal. However, court granted appellant 30 days from judgment receipt to file statutory appeal, directing appellate authority to accept it without limitation period restrictions. Court emphasized need for thorough factual adjudication through proper appellate channels rather than direct judicial intervention.
HC examined a challenge to an adjudication order allegedly issued without providing hearing opportunity. Despite claims of natural justice violation, the court found extensive documentation requiring detailed factual analysis. Determining this was not an exceptional case warranting bypass of statutory appeal mechanisms, HC dismissed the appeal. However, court granted appellant 30 days from judgment receipt to file statutory appeal, directing appellate authority to accept it without limitation period restrictions. Court emphasized need for thorough factual adjudication through proper appellate channels rather than direct judicial intervention.
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