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 show cause notice (SCN) issued on 27th September, 2023, was not properly communicated to the petitioner, violating principles of natural justice. Following precedent in a similar case, the court remanded the matter back to the adjudicating authority. The impugned order was set aside, and the petitioner was granted time until 10th July 2025, to file a reply to the SCN. The court directed that hearing notices must be e-mailed to the petitioner and not merely uploaded on the portal, ensuring proper opportunity to be heard.
HC held that the show cause notice (SCN) issued on 27th September, 2023, was not properly communicated to the petitioner, violating principles of natural justice. Following precedent in a similar case, the court remanded the matter back to the adjudicating authority. The impugned order was set aside, and the petitioner was granted time until 10th July 2025, to file a reply to the SCN. The court directed that hearing notices must be e-mailed to the petitioner and not merely uploaded on the portal, ensuring proper opportunity to be heard.
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