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 systemic administrative deficiencies in tax proceedings where petitioner's adjournment request was not properly recorded due to software synchronization issues. The court identified twin factors of portal technical errors and human negligence. Recognizing the constitutional mandate of tax collection, HC directed mandatory involvement of CIT(Judicial) as a nodal officer in future tax petitions. The court quashed penalty and demand orders dated 21.12.2021 that were passed despite existing stay orders, emphasizing the need for a just and humane tax administration system that balances departmental responsibilities with assessee rights.
HC found systemic administrative deficiencies in tax proceedings where petitioner's adjournment request was not properly recorded due to software synchronization issues. The court identified twin factors of portal technical errors and human negligence. Recognizing the constitutional mandate of tax collection, HC directed mandatory involvement of CIT(Judicial) as a nodal officer in future tax petitions. The court quashed penalty and demand orders dated 21.12.2021 that were passed despite existing stay orders, emphasizing the need for a just and humane tax administration system that balances departmental responsibilities with assessee rights.
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