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 held that issuance of a show-cause notice with one day's hearing notice and post-hearing/email communications violated the principles of natural justice. The writ petition was disposed of while declining to strike down the SCN on jurisdictional grounds. The Petitioner is directed to file a substantive reply to the SCN within 30 days (deadline: 30 September 2025). The Department shall grant the Petitioner a personal hearing, and the Adjudicating Authority must thereafter pass a detailed, reasoned order. No other relief granted; procedural non-compliance remedied by affording adequate time and hearing before further adjudication.
The HC held that issuance of a show-cause notice with one day's hearing notice and post-hearing/email communications violated the principles of natural justice. The writ petition was disposed of while declining to strike down the SCN on jurisdictional grounds. The Petitioner is directed to file a substantive reply to the SCN within 30 days (deadline: 30 September 2025). The Department shall grant the Petitioner a personal hearing, and the Adjudicating Authority must thereafter pass a detailed, reasoned order. No other relief granted; procedural non-compliance remedied by affording adequate time and hearing before further adjudication.
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