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 allowed the writ petitions by quashing the impugned assessment orders and remitting the matters to the respondents for fresh adjudication on merits. The court noted the petitioners' failure to respond to preceding show-cause notices and considered the applicability of notifications issued under Section 168A. In view of a recent decision of the Principal Bench invalidating the impugned Section 168A notification with consequential directions, the HC set aside the assessments without deciding substantive tax liability and directed the respondents to proceed afresh, observing that consequential statutory and procedural safeguards be afforded on reconsideration. The writ petitions are disposed of accordingly.
The HC allowed the writ petitions by quashing the impugned assessment orders and remitting the matters to the respondents for fresh adjudication on merits. The court noted the petitioners' failure to respond to preceding show-cause notices and considered the applicability of notifications issued under Section 168A. In view of a recent decision of the Principal Bench invalidating the impugned Section 168A notification with consequential directions, the HC set aside the assessments without deciding substantive tax liability and directed the respondents to proceed afresh, observing that consequential statutory and procedural safeguards be afforded on reconsideration. The writ petitions are disposed of accordingly.
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