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 set aside the ex parte assessment order dated 21 February 2025 passed under s.73 of the GST Act against the petitioner, finding failure of service of statutory notices (GST ASMT-10/ASMT-11) and denial of opportunity to be heard contrary to principles of natural justice. The writ petition was disposed directing the relevant authority to serve the outstanding documents upon the petitioner within seven days and afford an opportunity to file replies/explanations; further proceedings under s.73 are to proceed thereafter in accordance with law. The order compels fresh adjudication only after valid service and compliance with hearing requirements.
The HC set aside the ex parte assessment order dated 21 February 2025 passed under s.73 of the GST Act against the petitioner, finding failure of service of statutory notices (GST ASMT-10/ASMT-11) and denial of opportunity to be heard contrary to principles of natural justice. The writ petition was disposed directing the relevant authority to serve the outstanding documents upon the petitioner within seven days and afford an opportunity to file replies/explanations; further proceedings under s.73 are to proceed thereafter in accordance with law. The order compels fresh adjudication only after valid service and compliance with hearing requirements.
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