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...
Ex parte tax adjudication was set aside where the assessee had not been given a reasonable opportunity of hearing and the order was not reasoned. The HC followed earlier coordinate Bench rulings, quashed the impugned orders, and remitted the matter for fresh adjudication by a proper officer other than the original officer from the stage of reply to the show-cause notice. Liberty was granted to file additional material, and the authority was directed to afford a reasonable hearing and pass a speaking order.
Ex parte tax adjudication was set aside where the assessee had not been given a reasonable opportunity of hearing and the order was not reasoned. The HC followed earlier coordinate Bench rulings, quashed the impugned orders, and remitted the matter for fresh adjudication by a proper officer other than the original officer from the stage of reply to the show-cause notice. Liberty was granted to file additional material, and the authority was directed to afford a reasonable hearing and pass a speaking order.
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