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 as the petitioner was not afforded an opportunity to respond to the Show Cause Notice (SCN). The court remanded the matter back to the concerned department, directing it to provide the petitioner a fair hearing. The petitioner was granted 30 days to file a response to the SCN, ensuring procedural fairness and the right to be heard. The petition was disposed of through remand, allowing for a fresh consideration of the case with proper adherence to principles of natural justice.
HC found a violation of natural justice principles as the petitioner was not afforded an opportunity to respond to the Show Cause Notice (SCN). The court remanded the matter back to the concerned department, directing it to provide the petitioner a fair hearing. The petitioner was granted 30 days to file a response to the SCN, ensuring procedural fairness and the right to be heard. The petition was disposed of through remand, allowing for a fresh consideration of the case with proper adherence to principles of natural justice.
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