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...
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Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
The HC allowed the petition, set aside the impugned order dated 06.01.2025 and remanded the matter to the AO for fresh proceedings in accordance with law. The court accepted that although an appeal had been initially rejected on limitation grounds, the validity of the underlying order was vitiated by non-inclusion of the DIN as required under the GST Act and related administrative instructions; consequently the impugned order is treated as invalid and requires fresh adjudication. The AO is directed to proceed afresh, ensuring statutory formalities (including DIN compliance) are observed and to decide the matter on merits within the statutory framework.
The HC allowed the petition, set aside the impugned order dated 06.01.2025 and remanded the matter to the AO for fresh proceedings in accordance with law. The court accepted that although an appeal had been initially rejected on limitation grounds, the validity of the underlying order was vitiated by non-inclusion of the DIN as required under the GST Act and related administrative instructions; consequently the impugned order is treated as invalid and requires fresh adjudication. The AO is directed to proceed afresh, ensuring statutory formalities (including DIN compliance) are observed and to decide the matter on merits within the statutory framework.
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