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 allowed the writ petition, finding a violation of principles of natural justice. The court remanded the matter back to the Adjudicating Authority, granting the Petitioner time until 10th July 2025 to file a reply to the Show Cause Notice (SCN). The Adjudicating Authority must issue a personal hearing notice to the Petitioner after the reply is filed, effectively providing an opportunity to be heard that was previously denied.
HC allowed the writ petition, finding a violation of principles of natural justice. The court remanded the matter back to the Adjudicating Authority, granting the Petitioner time until 10th July 2025 to file a reply to the Show Cause Notice (SCN). The Adjudicating Authority must issue a personal hearing notice to the Petitioner after the reply is filed, effectively providing an opportunity to be heard that was previously denied.
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