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...
HC dismissed the writ petition as premature, finding the petitioner's challenge to the departmental show-cause notice unsuited to judicial adjudication absent an administrative reply and supporting documentary evidence. The court held that factual and taxability issues concerning the overseas construction contract and place-of-supply determinations are for the Assessing Officer to examine after receipt of a detailed response; accordingly the petitioner was granted liberty to file a comprehensive reply with all supporting documents in relation to the impugned show-cause notice dated 22.07.2024. The petition is dismissed, with the petitioner directed to submit its reply within 30 days of receipt of the order.
HC dismissed the writ petition as premature, finding the petitioner's challenge to the departmental show-cause notice unsuited to judicial adjudication absent an administrative reply and supporting documentary evidence. The court held that factual and taxability issues concerning the overseas construction contract and place-of-supply determinations are for the Assessing Officer to examine after receipt of a detailed response; accordingly the petitioner was granted liberty to file a comprehensive reply with all supporting documents in relation to the impugned show-cause notice dated 22.07.2024. The petition is dismissed, with the petitioner directed to submit its reply within 30 days of receipt of the order.
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