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 adjudicated a case involving multiple Show Cause Notices (SCNs) with overlapping assessment periods. The court acknowledged existing final assessment orders and stipulated that any subsequent order would be contingent upon the writ petition's ultimate outcome. The respondents were mandated to submit written replies within three weeks, with the petitioner granted two additional weeks to file a rejoinder affidavit. The matter was scheduled for further hearing on 19.03.2025, effectively maintaining procedural continuity while preserving the petitioner's right to challenge the assessment orders through the pending writ petition.
HC adjudicated a case involving multiple Show Cause Notices (SCNs) with overlapping assessment periods. The court acknowledged existing final assessment orders and stipulated that any subsequent order would be contingent upon the writ petition's ultimate outcome. The respondents were mandated to submit written replies within three weeks, with the petitioner granted two additional weeks to file a rejoinder affidavit. The matter was scheduled for further hearing on 19.03.2025, effectively maintaining procedural continuity while preserving the petitioner's right to challenge the assessment orders through the pending writ petition.
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