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...
Show cause notices must quantify interest liability before demanding it; failure to quantify interest for the specified period in the notice violated the statutory requirement and rendered both the notice and subsequent adjudication order invalid. The court distinguished liability quantified in orders from liability that must be specified in notices, holding that provisions addressing unquantified interest in orders do not cure an unquantified notice. Consequently the impugned notice and demand were quashed, with liberty for tax authorities to issue a fresh, properly quantified show cause notice and proceed in accordance with law.
Show cause notices must quantify interest liability before demanding it; failure to quantify interest for the specified period in the notice violated the statutory requirement and rendered both the notice and subsequent adjudication order invalid. The court distinguished liability quantified in orders from liability that must be specified in notices, holding that provisions addressing unquantified interest in orders do not cure an unquantified notice. Consequently the impugned notice and demand were quashed, with liberty for tax authorities to issue a fresh, properly quantified show cause notice and proceed in accordance with law.
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