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 rectification application was improperly processed due to violation of principles of natural justice by denying the petitioner an opportunity of hearing. Relying on prior judicial precedent, the court set aside the original order dated 28th February, 2025 and directed that the rectification application be reconsidered after providing a proper hearing to the petitioner in accordance with established legal principles. The petition was consequently disposed of with instructions for procedural compliance.
HC held that the rectification application was improperly processed due to violation of principles of natural justice by denying the petitioner an opportunity of hearing. Relying on prior judicial precedent, the court set aside the original order dated 28th February, 2025 and directed that the rectification application be reconsidered after providing a proper hearing to the petitioner in accordance with established legal principles. The petition was consequently disposed of with instructions for procedural compliance.
Note: It is a system-generated summary and is for quick reference only.