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 dismissed the petitions and upheld the impugned orders, finding that the petitioner failed to rebut the intimations that he migrated from the composition scheme to the regular scheme. The record established non-response to show-cause notices, no filing of returns, and non-payment of tax; no evidence was produced demonstrating any challenge to the intimation, reversal by a competent forum, or continued status as a composition taxpayer. Having neither responded to statutory notices nor appeared before the proper officer, the petitioner's belated assertion on appeal that he never opted out of the composition scheme was held to be unsubstantiated and insufficient to vitiate the impugned action. Petition dismissed.
The HC dismissed the petitions and upheld the impugned orders, finding that the petitioner failed to rebut the intimations that he migrated from the composition scheme to the regular scheme. The record established non-response to show-cause notices, no filing of returns, and non-payment of tax; no evidence was produced demonstrating any challenge to the intimation, reversal by a competent forum, or continued status as a composition taxpayer. Having neither responded to statutory notices nor appeared before the proper officer, the petitioner's belated assertion on appeal that he never opted out of the composition scheme was held to be unsubstantiated and insufficient to vitiate the impugned action. Petition dismissed.
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