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 the service of notices via email address listed on MCA website was valid and compliant with procedural rules. The petitioner received and responded to the scrutiny notice, thereby acknowledging awareness of assessment proceedings. Section 292BB was applicable as the petitioner participated in the inquiry and cannot subsequently challenge notice service. The court found no violation of natural justice principles, rejecting the petitioner's contention of improper notice service. The assessment order was upheld, with the court emphasizing that the petitioner's partial response and subsequent non-compliance undermined its procedural objections.
HC held that the service of notices via email address listed on MCA website was valid and compliant with procedural rules. The petitioner received and responded to the scrutiny notice, thereby acknowledging awareness of assessment proceedings. Section 292BB was applicable as the petitioner participated in the inquiry and cannot subsequently challenge notice service. The court found no violation of natural justice principles, rejecting the petitioner's contention of improper notice service. The assessment order was upheld, with the court emphasizing that the petitioner's partial response and subsequent non-compliance undermined its procedural objections.
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