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 and set aside the Appellate Order, the dismissal of the revocation application and the order of cancellation of registration, finding a breach of the principles of natural justice in that no hearing was afforded and the notices and orders lacked reasons. The matter is remitted with liberty to R2 to issue a fresh show-cause notice specifying particulars and reasons, to afford P a reasonable opportunity of hearing, and thereafter to pass a reasoned speaking order on the merits. The petition is allowed solely on natural justice grounds, following the Court's analogous reasoning in the coordinate bench authority.
The HC quashed and set aside the Appellate Order, the dismissal of the revocation application and the order of cancellation of registration, finding a breach of the principles of natural justice in that no hearing was afforded and the notices and orders lacked reasons. The matter is remitted with liberty to R2 to issue a fresh show-cause notice specifying particulars and reasons, to afford P a reasonable opportunity of hearing, and thereafter to pass a reasoned speaking order on the merits. The petition is allowed solely on natural justice grounds, following the Court's analogous reasoning in the coordinate bench authority.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4794
Join Channel
TaxTMI 
