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 dismissed petitioner's application under Section 161 of Goods and Services Act, 2017, holding that principles of natural justice are not mandatory when no actual rectification is performed and the applicant suffers no adverse impact. The court determined that the rectification provision requires adherence to natural justice only when specific conditions are met: (i) rectification is being carried out and (ii) such rectification potentially adversely affects the assessee. In this instance, the application was deemed vague and without substantive grounds, thus justifying rejection without a personal hearing.
HC dismissed petitioner's application under Section 161 of Goods and Services Act, 2017, holding that principles of natural justice are not mandatory when no actual rectification is performed and the applicant suffers no adverse impact. The court determined that the rectification provision requires adherence to natural justice only when specific conditions are met: (i) rectification is being carried out and (ii) such rectification potentially adversely affects the assessee. In this instance, the application was deemed vague and without substantive grounds, thus justifying rejection without a personal hearing.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4800
Join Channel
TaxTMI 
