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 assessment order dated 14.08.2024 for violation of natural justice principles where petitioner was denied personal hearing opportunity. Though show cause notice was uploaded on GST Portal constituting valid service, respondent failed to explore alternative service modes under Section 169 GST Act when petitioner remained non-responsive. Court held that officers must utilize other prescribed service methods like RPAD when portal service proves ineffective to avoid empty formalities and multiplicity of litigation. Matter remanded to respondent for fresh consideration conditional upon petitioner depositing 25% of disputed tax amount within four weeks. Petition allowed by way of remand emphasizing effective service requirements over mere procedural compliance.
HC set aside assessment order dated 14.08.2024 for violation of natural justice principles where petitioner was denied personal hearing opportunity. Though show cause notice was uploaded on GST Portal constituting valid service, respondent failed to explore alternative service modes under Section 169 GST Act when petitioner remained non-responsive. Court held that officers must utilize other prescribed service methods like RPAD when portal service proves ineffective to avoid empty formalities and multiplicity of litigation. Matter remanded to respondent for fresh consideration conditional upon petitioner depositing 25% of disputed tax amount within four weeks. Petition allowed by way of remand emphasizing effective service requirements over mere procedural compliance.
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