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 orders dated 21.12.2024 and remitted the matters to the first respondent for fresh adjudication on merits and in accordance with law. The court observed that the second respondent correctly rejected the belated appeals filed 62 days beyond the condonable period, given the petitioner's failure to respond to show-cause notices or appear for personal hearing; however, in view of the petitioner having deposited 100% of disputed tax for October and December 2023 and 10% for November 2023, equity warranted relief. The petitioner is directed to pay an additional 15% of the disputed tax for November 2023 in cash via Electronic Cash Register within 30 days of receipt of this order. Petition disposed.
The HC quashed the impugned orders dated 21.12.2024 and remitted the matters to the first respondent for fresh adjudication on merits and in accordance with law. The court observed that the second respondent correctly rejected the belated appeals filed 62 days beyond the condonable period, given the petitioner's failure to respond to show-cause notices or appear for personal hearing; however, in view of the petitioner having deposited 100% of disputed tax for October and December 2023 and 10% for November 2023, equity warranted relief. The petitioner is directed to pay an additional 15% of the disputed tax for November 2023 in cash via Electronic Cash Register within 30 days of receipt of this order. Petition disposed.
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