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 where respondent issued a personal hearing notice before reply deadline and subsequently passed an order without considering petitioner's detailed reply. The impugned order was contrary to Section 75(4) of GST Act, as the petitioner was not provided a meaningful opportunity to be heard. The HC set aside the order dated 30.04.2024 and remanded the matter for fresh consideration, ensuring procedural fairness and adherence to principles of natural justice in administrative proceedings.
HC found a violation of natural justice where respondent issued a personal hearing notice before reply deadline and subsequently passed an order without considering petitioner's detailed reply. The impugned order was contrary to Section 75(4) of GST Act, as the petitioner was not provided a meaningful opportunity to be heard. The HC set aside the order dated 30.04.2024 and remanded the matter for fresh consideration, ensuring procedural fairness and adherence to principles of natural justice in administrative proceedings.
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