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 a violation of natural justice principles in the GST assessment order. The respondent issued a show-cause notice and scheduled a hearing, but failed to consider the petitioner's adjournment request and supporting documentation. Consequently, the court set aside the impugned order (Form GST DRC-07) dated 23.08.2024, determining that the administrative action did not provide adequate opportunity for the petitioner to present a comprehensive defense, thereby breaching fundamental procedural fairness.
HC found a violation of natural justice principles in the GST assessment order. The respondent issued a show-cause notice and scheduled a hearing, but failed to consider the petitioner's adjournment request and supporting documentation. Consequently, the court set aside the impugned order (Form GST DRC-07) dated 23.08.2024, determining that the administrative action did not provide adequate opportunity for the petitioner to present a comprehensive defense, thereby breaching fundamental procedural fairness.
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