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 allowed the petition, holding that the revisional order dated 22 July 2024 is vitiated by want of valid service of the show-cause notice dated 1 July 2024 and by a consequent breach of the principles of natural justice; accordingly, the impugned revisional order is set aside. The court confined its decision to the procedural defect and permitted the Respondent to proceed afresh with the show-cause proceedings: to effect valid service of the 1 July 2024 notice, afford the Petitioner an opportunity of hearing, and thereafter pass appropriate orders in accordance with law. The petition is allowed; the show-cause notice was not annexed to the Respondent's replies.
The HC allowed the petition, holding that the revisional order dated 22 July 2024 is vitiated by want of valid service of the show-cause notice dated 1 July 2024 and by a consequent breach of the principles of natural justice; accordingly, the impugned revisional order is set aside. The court confined its decision to the procedural defect and permitted the Respondent to proceed afresh with the show-cause proceedings: to effect valid service of the 1 July 2024 notice, afford the Petitioner an opportunity of hearing, and thereafter pass appropriate orders in accordance with law. The petition is allowed; the show-cause notice was not annexed to the Respondent's replies.
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