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...
HC set aside the order-in-appeal dated 20.06.2025 on the ground that the appellate authority failed to consider or discuss the grounds raised in the memo of appeal, constituting a violation of the principles of natural justice and rendering the impugned order reasonless. The matter is remitted to the appellate authority for decision by a fresh, reasoned order in accordance with law. The petitioner is directed to appear before the appellate authority on 06.10.2025. The petition is disposed of by remand.
HC set aside the order-in-appeal dated 20.06.2025 on the ground that the appellate authority failed to consider or discuss the grounds raised in the memo of appeal, constituting a violation of the principles of natural justice and rendering the impugned order reasonless. The matter is remitted to the appellate authority for decision by a fresh, reasoned order in accordance with law. The petitioner is directed to appear before the appellate authority on 06.10.2025. The petition is disposed of by remand.
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