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 writ petition filed by the petitioner challenging issuance of DRC-01, holding that the department did not accept the petitioner's initial reply and issued DRC-01; once the petitioner files a substantive reply to DRC-01 the department must pass a detailed, speaking order explaining reasons for any rejection. The court declined to adjudicate the underlying tax adjustment dispute at this interim stage and refused relief, but granted the petitioner liberty to file a reply to DRC-01 within two weeks of receipt of the order. On receipt, respondents must consider and decide the matter by a reasoned order within four weeks. Petition dismissed.
The HC dismissed the writ petition filed by the petitioner challenging issuance of DRC-01, holding that the department did not accept the petitioner's initial reply and issued DRC-01; once the petitioner files a substantive reply to DRC-01 the department must pass a detailed, speaking order explaining reasons for any rejection. The court declined to adjudicate the underlying tax adjustment dispute at this interim stage and refused relief, but granted the petitioner liberty to file a reply to DRC-01 within two weeks of receipt of the order. On receipt, respondents must consider and decide the matter by a reasoned order within four weeks. Petition dismissed.
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