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 assessment order must bear a signature, and an unsigned order is invalid. The High Court also recognised practical difficulties in accessing orders uploaded on the portal and held that delay in invoking writ jurisdiction can be overlooked where the assessment suffers from a patent irregularity, while balancing taxpayer hardship against revenue protection. The unsigned assessment orders were set aside and the matter was remanded for fresh assessment after hearing, subject to deposit of 20% of the disputed tax, adjustment of amounts already paid or recovered, and exclusion of the writ period for limitation.
An assessment order must bear a signature, and an unsigned order is invalid. The High Court also recognised practical difficulties in accessing orders uploaded on the portal and held that delay in invoking writ jurisdiction can be overlooked where the assessment suffers from a patent irregularity, while balancing taxpayer hardship against revenue protection. The unsigned assessment orders were set aside and the matter was remanded for fresh assessment after hearing, subject to deposit of 20% of the disputed tax, adjustment of amounts already paid or recovered, and exclusion of the writ period for limitation.
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