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 remanded the matter concerning SCN No. 09/2023 due to procedural irregularities in notice service. The court noted that prior to 16th January 2024, show cause notices were uploaded in 'Additional Notices Tab', potentially preventing proper access. Considering the petitioner did not receive adequate opportunity to be heard, the HC directed the adjudicating authority to provide fresh notice. The petitioner was granted time until 15th July 2025 to file reply, with a mandatory personal hearing to be scheduled after submission. The original impugned order was set aside, and the petition was disposed of accordingly.
HC remanded the matter concerning SCN No. 09/2023 due to procedural irregularities in notice service. The court noted that prior to 16th January 2024, show cause notices were uploaded in 'Additional Notices Tab', potentially preventing proper access. Considering the petitioner did not receive adequate opportunity to be heard, the HC directed the adjudicating authority to provide fresh notice. The petitioner was granted time until 15th July 2025 to file reply, with a mandatory personal hearing to be scheduled after submission. The original impugned order was set aside, and the petition was disposed of accordingly.
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