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...
Validity of reopening of assessment was examined and the impugned reassessment order was quashed because the stated reasons for reopening did not align with the reasons in the order; the matter is remitted for fresh adjudication. The remand requires the assessing authority to afford the taxpayer another opportunity to file a detailed reply with supporting documents and to decide the matter on merits in accordance with law. The impugned order is to be treated as an addendum to the pre-assessment show cause notice and the petitioner must upload its reply when the portal permits; writ petition disposed.
Validity of reopening of assessment was examined and the impugned reassessment order was quashed because the stated reasons for reopening did not align with the reasons in the order; the matter is remitted for fresh adjudication. The remand requires the assessing authority to afford the taxpayer another opportunity to file a detailed reply with supporting documents and to decide the matter on merits in accordance with law. The impugned order is to be treated as an addendum to the pre-assessment show cause notice and the petitioner must upload its reply when the portal permits; writ petition disposed.
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