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...
An order issued and adjudications made against a deceased person are void (non est) and liable to be set aside; where legal heirs step forward to represent the deceased's estate and undertake to file replies to show cause notices, the proper remedy is remand for fresh consideration with an opportunity for personal hearing after issuance of fresh notice. The impugned orders were therefore set aside and the matters remanded for reconsideration in light of representation by the legal heirs.
An order issued and adjudications made against a deceased person are void (non est) and liable to be set aside; where legal heirs step forward to represent the deceased's estate and undertake to file replies to show cause notices, the proper remedy is remand for fresh consideration with an opportunity for personal hearing after issuance of fresh notice. The impugned orders were therefore set aside and the matters remanded for reconsideration in light of representation by the legal heirs.
Note: It is a system-generated summary and is for quick reference only.