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 quashed the impugned Assessment Order dated 12.02.2025 and remitted the matter to the 2nd Respondent for fresh adjudication. The remittal is conditional: the Petitioner must deposit 25% of the disputed tax in cash from the Petitioner's Electronic Cash Register within thirty days of receipt of the order. The HC observed that similar relief had been granted previously under analogous circumstances and found no reason for a different approach. The petition is disposed of by way of remand, subject to compliance with the deposit condition, failing which the Respondent may proceed in accordance with law.
The HC quashed the impugned Assessment Order dated 12.02.2025 and remitted the matter to the 2nd Respondent for fresh adjudication. The remittal is conditional: the Petitioner must deposit 25% of the disputed tax in cash from the Petitioner's Electronic Cash Register within thirty days of receipt of the order. The HC observed that similar relief had been granted previously under analogous circumstances and found no reason for a different approach. The petition is disposed of by way of remand, subject to compliance with the deposit condition, failing which the Respondent may proceed in accordance with law.
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