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 set aside the impugned orders and quashed the appellate rejection based solely on delay, holding that the petitioner was entitled to a reasonable opportunity to adduce material evidence concerning GST exemption on specified rice transactions. The court directed the petitioner to produce invoices and corroborative evidence within two months and ordered the competent authority to schedule an oral hearing, consider the newly produced material, and pass a fresh speaking order within four months. The matter is remitted for fresh adjudication on merits limited to the exemption claim; petition allowed and prior orders dated 15.04.2025, 27.04.2024 and 28.04.2024 set aside.
HC set aside the impugned orders and quashed the appellate rejection based solely on delay, holding that the petitioner was entitled to a reasonable opportunity to adduce material evidence concerning GST exemption on specified rice transactions. The court directed the petitioner to produce invoices and corroborative evidence within two months and ordered the competent authority to schedule an oral hearing, consider the newly produced material, and pass a fresh speaking order within four months. The matter is remitted for fresh adjudication on merits limited to the exemption claim; petition allowed and prior orders dated 15.04.2025, 27.04.2024 and 28.04.2024 set aside.
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