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 found a breach of natural justice where show-cause notices and orders under s.73 were only uploaded to the GST portal's "Additional Notices and Orders" tab, depriving the petitioner of effective service and opportunity to be heard; noting the disputed amount was deposited and no outstanding demand existed, the Court quashed and set aside the impugned order dated December 23, 2023, allowed the writ petition and directed that the petitioner may treat the impugned order as the final notice and submit a written reply within two weeks. The remedy was granted without relegation to alternative statutory remedies given the service failure.
The HC found a breach of natural justice where show-cause notices and orders under s.73 were only uploaded to the GST portal's "Additional Notices and Orders" tab, depriving the petitioner of effective service and opportunity to be heard; noting the disputed amount was deposited and no outstanding demand existed, the Court quashed and set aside the impugned order dated December 23, 2023, allowed the writ petition and directed that the petitioner may treat the impugned order as the final notice and submit a written reply within two weeks. The remedy was granted without relegation to alternative statutory remedies given the service failure.
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