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 found no violation of natural justice principles in the appellate proceedings. The authority had fully complied with Section 107(9) by granting the petitioner adequate hearing opportunity. Upon examination, all procedural requirements were properly followed, and the appellate authority had thoroughly considered every ground raised by the petitioner in its decision dated 22nd November 2024. The Court determined there was no oversight of material aspects or breach of procedural fairness in the appellate authority's decision-making process. The petition challenging the appellate order on grounds of natural justice violation was accordingly dismissed.
HC found no violation of natural justice principles in the appellate proceedings. The authority had fully complied with Section 107(9) by granting the petitioner adequate hearing opportunity. Upon examination, all procedural requirements were properly followed, and the appellate authority had thoroughly considered every ground raised by the petitioner in its decision dated 22nd November 2024. The Court determined there was no oversight of material aspects or breach of procedural fairness in the appellate authority's decision-making process. The petition challenging the appellate order on grounds of natural justice violation was accordingly dismissed.
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