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...
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Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
The HC set aside the assessment order and remanded the matter to the assessing authority for fresh consideration. The court found violation of natural justice principles as the respondent failed to properly consider the petitioner's objections regarding whether trial balances included only intra-state supplies or also inter-state supplies from Andhra Pradesh. The authority also failed to account for invoices with proper endorsements relating to supplies made to SEZ units. The court held that non-consideration of the petitioner's objections was established, necessitating remand for re-appreciation of grounds raised and verification of invoices and documents submitted for liability reduction. The petition was disposed of through remand proceedings.
The HC set aside the assessment order and remanded the matter to the assessing authority for fresh consideration. The court found violation of natural justice principles as the respondent failed to properly consider the petitioner's objections regarding whether trial balances included only intra-state supplies or also inter-state supplies from Andhra Pradesh. The authority also failed to account for invoices with proper endorsements relating to supplies made to SEZ units. The court held that non-consideration of the petitioner's objections was established, necessitating remand for re-appreciation of grounds raised and verification of invoices and documents submitted for liability reduction. The petition was disposed of through remand proceedings.
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