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 quashed ex-parte demand orders dated 28.12.2023 and 11.07.2023 as time-barred under Section 73(9), referencing precedent in M/s Anita Traders case. The court determined that the impugned orders were issued beyond the jurisdictional time limitation for the financial year 2017-18, violating principles of natural justice. The orders were consequently invalidated, with the petitioner's challenge successfully upheld, thereby rendering the statutory notices null and void.
HC quashed ex-parte demand orders dated 28.12.2023 and 11.07.2023 as time-barred under Section 73(9), referencing precedent in M/s Anita Traders case. The court determined that the impugned orders were issued beyond the jurisdictional time limitation for the financial year 2017-18, violating principles of natural justice. The orders were consequently invalidated, with the petitioner's challenge successfully upheld, thereby rendering the statutory notices null and void.
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