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 quashed the summary of show cause notice and order for procedural violations under AGST Act, 2017. The court found that issuing a summary notice without providing an opportunity of hearing constituted a breach of natural justice principles. Following precedent in a similar case, the HC set aside the impugned orders and granted authorities liberty to initiate de novo proceedings under Section 73, if deemed appropriate. The decision emphasizes procedural fairness and the requirement of proper legal process in tax determination proceedings.
HC quashed the summary of show cause notice and order for procedural violations under AGST Act, 2017. The court found that issuing a summary notice without providing an opportunity of hearing constituted a breach of natural justice principles. Following precedent in a similar case, the HC set aside the impugned orders and granted authorities liberty to initiate de novo proceedings under Section 73, if deemed appropriate. The decision emphasizes procedural fairness and the requirement of proper legal process in tax determination proceedings.
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