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 appeals and upheld the learned Single Judge's disposition allowing the writ petitions to the extent of relegating the petitioners to the post show-cause notice stage. The Court declined to adjudicate merits on liability or exemption under service tax, deeming such issues premature and fact-intensive, and found no jurisdictional error warranting interference with the show cause notices. In certain matters the Court set aside impugned orders-in-original and restored proceedings to the stage of post show-cause notice, granting petitioners liberty to file reply and additional reply as appropriate. The appeals are rejected and the administrative adjudicatory process is remitted for fresh consideration.
The HC dismissed the writ appeals and upheld the learned Single Judge's disposition allowing the writ petitions to the extent of relegating the petitioners to the post show-cause notice stage. The Court declined to adjudicate merits on liability or exemption under service tax, deeming such issues premature and fact-intensive, and found no jurisdictional error warranting interference with the show cause notices. In certain matters the Court set aside impugned orders-in-original and restored proceedings to the stage of post show-cause notice, granting petitioners liberty to file reply and additional reply as appropriate. The appeals are rejected and the administrative adjudicatory process is remitted for fresh consideration.
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