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 16.02.2024 and remitted the matter to the 2nd Respondent for fresh adjudication after observing that the Petitioner failed to respond to the SCN dated 30.12.2023 and subsequent notices. Consistent with precedent, remand is conditioned upon the Petitioner's additional pre-deposit of 15% of the disputed tax in cash from the Petitioner's Electronic Cash Register/Electronic Credit Ledger, over and above the 10% already deposited before the Appellate Authority, such that total pre-deposit equals 25%. The 15% cash deposit must be made within 30 days of receipt of this order. Petition disposed by way of remand.
The HC quashed the impugned assessment order dated 16.02.2024 and remitted the matter to the 2nd Respondent for fresh adjudication after observing that the Petitioner failed to respond to the SCN dated 30.12.2023 and subsequent notices. Consistent with precedent, remand is conditioned upon the Petitioner's additional pre-deposit of 15% of the disputed tax in cash from the Petitioner's Electronic Cash Register/Electronic Credit Ledger, over and above the 10% already deposited before the Appellate Authority, such that total pre-deposit equals 25%. The 15% cash deposit must be made within 30 days of receipt of this order. Petition disposed by way of remand.
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