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 disposed of the writ petition by quashing the impugned order, acknowledging the petitioner's failure to respond to the notice in DRC 01. The Court, following its prior approach in similar cases, granted relief on terms rather than outright dismissal. The petitioner was directed to deposit 25% of the disputed tax in cash from the Electronic Cash Register within thirty days from receipt of the order. This conditional quashing balances the petitioner's non-compliance with procedural requirements while providing an opportunity to regularize the disputed tax liability.
The HC disposed of the writ petition by quashing the impugned order, acknowledging the petitioner's failure to respond to the notice in DRC 01. The Court, following its prior approach in similar cases, granted relief on terms rather than outright dismissal. The petitioner was directed to deposit 25% of the disputed tax in cash from the Electronic Cash Register within thirty days from receipt of the order. This conditional quashing balances the petitioner's non-compliance with procedural requirements while providing an opportunity to regularize the disputed tax liability.
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