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 the appeal involving tax computation for the period 1st April 2018 to 31st March 2019, where the original order was passed ex parte due to non-response to show cause notice. Despite time limitation challenges, the court determined that remanding the matter to the appellate authority would be most appropriate. The HC noted the electronic availability of records and the potential for more efficient factual assessment by the appellate authority. Consequently, the petition was disposed of by remanding the case back to the appellate authority for substantive merit-based adjudication, effectively providing the petitioner an opportunity to present their case and challenge the original tax order.
HC dismissed the appeal involving tax computation for the period 1st April 2018 to 31st March 2019, where the original order was passed ex parte due to non-response to show cause notice. Despite time limitation challenges, the court determined that remanding the matter to the appellate authority would be most appropriate. The HC noted the electronic availability of records and the potential for more efficient factual assessment by the appellate authority. Consequently, the petition was disposed of by remanding the case back to the appellate authority for substantive merit-based adjudication, effectively providing the petitioner an opportunity to present their case and challenge the original tax order.
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