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...
Ratification of resignation acceptance validates separation retrospectively, while withdrawal may be refused through reasoned administrative discretio...
The rectification order was set aside for breach of natural justice because it had been passed without affording the petitioner a hearing and without considering its submissions and documents. The Court treated this procedural illegality as the ative defect and directed de novo consideration by the designated authority. The authority was permitted to issue a fresh show cause notice, grant personal hearing, and pass a reasoned and speaking order, with all rival contentions left open for fresh adjudication.
The rectification order was set aside for breach of natural justice because it had been passed without affording the petitioner a hearing and without considering its submissions and documents. The Court treated this procedural illegality as the ative defect and directed de novo consideration by the designated authority. The authority was permitted to issue a fresh show cause notice, grant personal hearing, and pass a reasoned and speaking order, with all rival contentions left open for fresh adjudication.
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