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 petition in part, finding a violation of natural justice principles. The court set aside orders dated 20.09.2023 and 08.05.2024 for non-compliance with Section 169 of Bihar Goods and Service Act, 2017. The matter was remanded to the concerned authority to issue a fresh summary show-cause notice, providing the petitioner adequate opportunity to respond. The authority was directed to pass a reasoned order and communicate it within six months, recognizing that mere portal uploading of notice is insufficient and requires registered post or alternative communication modes.
HC allowed the petition in part, finding a violation of natural justice principles. The court set aside orders dated 20.09.2023 and 08.05.2024 for non-compliance with Section 169 of Bihar Goods and Service Act, 2017. The matter was remanded to the concerned authority to issue a fresh summary show-cause notice, providing the petitioner adequate opportunity to respond. The authority was directed to pass a reasoned order and communicate it within six months, recognizing that mere portal uploading of notice is insufficient and requires registered post or alternative communication modes.
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