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 impugned order due to non-application of mind and violation of natural justice principles. The petitioner had deposited 10% of the disputed tax and recovered over 25% during proceedings. The matter was remanded to the respondents to pass fresh orders on merits and in accordance with law after affording the petitioner a hearing within three months. The petitioner is directed to file a reply to the show cause notice, treating the impugned order as an addendum, within 30 days of receiving this order. The petition was disposed of by remand.
The HC quashed the impugned order due to non-application of mind and violation of natural justice principles. The petitioner had deposited 10% of the disputed tax and recovered over 25% during proceedings. The matter was remanded to the respondents to pass fresh orders on merits and in accordance with law after affording the petitioner a hearing within three months. The petitioner is directed to file a reply to the show cause notice, treating the impugned order as an addendum, within 30 days of receiving this order. The petition was disposed of by remand.
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