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...
Timelines prescribed under Regulation 17 of the Customs Brokers Licensing Regulations, 2018 were held mandatory, so a show cause notice for revocation had to be issued within ninety days of receipt of the offence report and the inquiry report within ninety days of the notice. As the offence report was received on 11.06.2023 but the notice was issued only on 29.06.2024, the notice was invalid for breach of the statutory timeline. The consequential inquiry report could not survive once the notice itself was void. The High Court therefore set aside both the show cause notice and the inquiry report for non-adherence to the mandatory time limits.
Timelines prescribed under Regulation 17 of the Customs Brokers Licensing Regulations, 2018 were held mandatory, so a show cause notice for revocation had to be issued within ninety days of receipt of the offence report and the inquiry report within ninety days of the notice. As the offence report was received on 11.06.2023 but the notice was issued only on 29.06.2024, the notice was invalid for breach of the statutory timeline. The consequential inquiry report could not survive once the notice itself was void. The High Court therefore set aside both the show cause notice and the inquiry report for non-adherence to the mandatory time limits.
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