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...
Where an assessment order was passed without affording a personal hearing and service was effected solely by portal upload, the article emphasises that an issuing officer must assess the effectiveness of service and, if portal notices elicit no response, explore other statutory modes of service (preferably registered post acknowledgement) before proceeding. Mere formal portal compliance leading to ex parte assessment undermines the GST scheme and multiplicity of litigation. The impugned assessment was set aside for defective procedure and the matter remitted for fresh consideration, conditional on the taxpayer depositing ten percent of the disputed tax and being given a clear 14 day notice for personal hearing.
Where an assessment order was passed without affording a personal hearing and service was effected solely by portal upload, the article emphasises that an issuing officer must assess the effectiveness of service and, if portal notices elicit no response, explore other statutory modes of service (preferably registered post acknowledgement) before proceeding. Mere formal portal compliance leading to ex parte assessment undermines the GST scheme and multiplicity of litigation. The impugned assessment was set aside for defective procedure and the matter remitted for fresh consideration, conditional on the taxpayer depositing ten percent of the disputed tax and being given a clear 14 day notice for personal hearing.
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