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 held that principles of natural justice were violated when petitioner was denied personal hearing despite sufficient time between response filing and order issuance. The authority failed to provide opportunity under Section 75(4), which mandates hearing before adverse order. Given potential substantive arguments in petitioner's response, the procedural defect was material. The impugned order was consequently set aside, with petition allowed, emphasizing the critical importance of procedural fairness in administrative proceedings.
HC held that principles of natural justice were violated when petitioner was denied personal hearing despite sufficient time between response filing and order issuance. The authority failed to provide opportunity under Section 75(4), which mandates hearing before adverse order. Given potential substantive arguments in petitioner's response, the procedural defect was material. The impugned order was consequently set aside, with petition allowed, emphasizing the critical importance of procedural fairness in administrative proceedings.
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