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...
The HC set aside the tax authority's order dated 07.05.2024 confirming the entire original tax demand against the petitioner. The court found that the impugned order failed to consider that petitioner had remitted 58% of the differential amount through electronic credit ledger debit. The HC held that no credit was given for this substantial remittance, necessitating reconsideration. The matter was remanded to the first respondent with directions to reconsider the tax demand after providing reasonable opportunity to the petitioner and accounting for remittances made via electronic credit ledger debit. The petition was disposed of by way of remand.
The HC set aside the tax authority's order dated 07.05.2024 confirming the entire original tax demand against the petitioner. The court found that the impugned order failed to consider that petitioner had remitted 58% of the differential amount through electronic credit ledger debit. The HC held that no credit was given for this substantial remittance, necessitating reconsideration. The matter was remanded to the first respondent with directions to reconsider the tax demand after providing reasonable opportunity to the petitioner and accounting for remittances made via electronic credit ledger debit. The petition was disposed of by way of remand.
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