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 held that the impugned orders were vitiated due to the absence of signatures on the DRC-07 document, which is a statutory requirement. The court emphasized that when a statute prescribes a specific mode of execution, compliance with that mode is mandatory, and any deviation renders the act invalid. The lack of signatures on DRC-01 and DRC-07 could not be overridden by explanations in the counter affidavit or notes. Consequently, the petition challenging the orders was disposed of in favor of the petitioner, affirming that non-compliance with statutory formalities invalidates the impugned orders.
The HC held that the impugned orders were vitiated due to the absence of signatures on the DRC-07 document, which is a statutory requirement. The court emphasized that when a statute prescribes a specific mode of execution, compliance with that mode is mandatory, and any deviation renders the act invalid. The lack of signatures on DRC-01 and DRC-07 could not be overridden by explanations in the counter affidavit or notes. Consequently, the petition challenging the orders was disposed of in favor of the petitioner, affirming that non-compliance with statutory formalities invalidates the impugned orders.
Note: It is a system-generated summary and is for quick reference only.