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 set aside the ex parte order passed under Section 107 of GST Act, finding procedural irregularities despite multiple hearing opportunities being provided to the petitioner. Although the petitioner's non-appearance through tax consultant was not fully justified, the appellate authority's order lacked substantive reasoning and did not comply with statutory requirements. The matter was remanded for fresh adjudication, ensuring principles of natural justice are followed and the case is re-examined on merits. Writ petition disposed of with directions for de novo proceedings before the appellate authority.
HC set aside the ex parte order passed under Section 107 of GST Act, finding procedural irregularities despite multiple hearing opportunities being provided to the petitioner. Although the petitioner's non-appearance through tax consultant was not fully justified, the appellate authority's order lacked substantive reasoning and did not comply with statutory requirements. The matter was remanded for fresh adjudication, ensuring principles of natural justice are followed and the case is re-examined on merits. Writ petition disposed of with directions for de novo proceedings before the appellate authority.
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