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 set aside the impugned order dated 30.06.2025, holding it to be a non-speaking order that violated principles of natural justice by failing to address the petitioner's explanations and objections. The impugned order is to be treated as a show cause notice; the petitioner may file objections with supporting documents within four weeks of receipt of this order. The first respondent/revenue is directed to issue requisite notice, afford an opportunity of hearing, reconsider the matter, and redo the assessment by passing a speaking order addressing the objections, input tax credit and stock variation issues. The petition is disposed of subject to compliance with these directions.
The HC set aside the impugned order dated 30.06.2025, holding it to be a non-speaking order that violated principles of natural justice by failing to address the petitioner's explanations and objections. The impugned order is to be treated as a show cause notice; the petitioner may file objections with supporting documents within four weeks of receipt of this order. The first respondent/revenue is directed to issue requisite notice, afford an opportunity of hearing, reconsider the matter, and redo the assessment by passing a speaking order addressing the objections, input tax credit and stock variation issues. The petition is disposed of subject to compliance with these directions.
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