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 service of notice via online GST portal under 'View Additional Notice/Orders' column is insufficient and violates principles of natural justice. The court invalidated the ex parte order due to improper notice service. Recommended alternative service methods including registered post with acknowledgement, hand delivery, or courier to taxpayer's last known address. The impugned order was set aside and the matter remanded to the respondent for fresh consideration, ensuring the petitioner receives proper legal notification and opportunity to be heard.
HC held that service of notice via online GST portal under 'View Additional Notice/Orders' column is insufficient and violates principles of natural justice. The court invalidated the ex parte order due to improper notice service. Recommended alternative service methods including registered post with acknowledgement, hand delivery, or courier to taxpayer's last known address. The impugned order was set aside and the matter remanded to the respondent for fresh consideration, ensuring the petitioner receives proper legal notification and opportunity to be heard.
Note: It is a system-generated summary and is for quick reference only.