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 issued a writ of mandamus directing the respondent to expeditiously consider and dispose of the petitioner's appeal filed on 13.02.2025, challenging the order regarding tax imposition and recovery of money allegedly obtained through unlawful means. The Court emphasized the necessity for the appellate authority to act in a time-bound manner and to decide the matter on merits in accordance with law, taking into account relevant judicial precedents cited by the petitioner. The petition was allowed, mandating cooperation from the respondent and ensuring the appeal process proceeds without undue delay.
The HC issued a writ of mandamus directing the respondent to expeditiously consider and dispose of the petitioner's appeal filed on 13.02.2025, challenging the order regarding tax imposition and recovery of money allegedly obtained through unlawful means. The Court emphasized the necessity for the appellate authority to act in a time-bound manner and to decide the matter on merits in accordance with law, taking into account relevant judicial precedents cited by the petitioner. The petition was allowed, mandating cooperation from the respondent and ensuring the appeal process proceeds without undue delay.
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