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...
The HC granted ad-interim relief to the petitioner in a case concerning a show cause notice (SCN) issued two days beyond the statutory deadline under Section 73(2). The court held prima facie that the time limits for issuing SCNs are mandatory, not directory, rendering the late notice legally invalid. Relying on precedent from the AP HC in Cotton Corporation, which established that violation of prescribed time periods makes an SCN otiose, the court determined this was a jurisdictional issue where the proper officer lacked authority to issue the delayed notice. The matter was scheduled for further hearing on April 22, 2025.
The HC granted ad-interim relief to the petitioner in a case concerning a show cause notice (SCN) issued two days beyond the statutory deadline under Section 73(2). The court held prima facie that the time limits for issuing SCNs are mandatory, not directory, rendering the late notice legally invalid. Relying on precedent from the AP HC in Cotton Corporation, which established that violation of prescribed time periods makes an SCN otiose, the court determined this was a jurisdictional issue where the proper officer lacked authority to issue the delayed notice. The matter was scheduled for further hearing on April 22, 2025.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4796
Join Channel
TaxTMI 
