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 dismissed the petitions on maintainability grounds, emphasizing the availability of an alternate and efficacious remedy by way of appeal. The court held that no patent breach of natural justice occurred, as the petitioners were served with show-cause notices and participated in the proceedings without raising the denial of hearing issue earlier. The refusal of adjournment did not amount to prejudice or a violation warranting departure from the rule of exhausting alternate remedies. The petitioners were granted liberty to file appeals against the impugned orders within six weeks, with a directive that the appellate authority consider the appeals on merits without raising limitation objections, given the bona fide prosecution of the petitions within limitation. The petitions were accordingly disposed of.
The HC dismissed the petitions on maintainability grounds, emphasizing the availability of an alternate and efficacious remedy by way of appeal. The court held that no patent breach of natural justice occurred, as the petitioners were served with show-cause notices and participated in the proceedings without raising the denial of hearing issue earlier. The refusal of adjournment did not amount to prejudice or a violation warranting departure from the rule of exhausting alternate remedies. The petitioners were granted liberty to file appeals against the impugned orders within six weeks, with a directive that the appellate authority consider the appeals on merits without raising limitation objections, given the bona fide prosecution of the petitions within limitation. The petitions were accordingly disposed of.
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