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 quashed the order blocking petitioner's Electronic Credit Ledger under Rule 86A, finding violation of natural justice principles. The court held that respondents failed to provide pre-decisional hearing and the impugned order lacked independent reasons to believe, impermissibly relying on borrowed satisfaction from enforcement authority reports. Following precedent in K-9-Enterprises, the court determined mandatory prerequisites under Rule 86A were not fulfilled, rendering the blocking order illegal and arbitrary. The HC directed immediate unblocking of petitioner's Electronic Credit Ledger upon receipt of the order to enable filing of returns. Petition was allowed with the impugned order being quashed entirely.
The HC quashed the order blocking petitioner's Electronic Credit Ledger under Rule 86A, finding violation of natural justice principles. The court held that respondents failed to provide pre-decisional hearing and the impugned order lacked independent reasons to believe, impermissibly relying on borrowed satisfaction from enforcement authority reports. Following precedent in K-9-Enterprises, the court determined mandatory prerequisites under Rule 86A were not fulfilled, rendering the blocking order illegal and arbitrary. The HC directed immediate unblocking of petitioner's Electronic Credit Ledger upon receipt of the order to enable filing of returns. Petition was allowed with the impugned order being quashed entirely.
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