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...
Assessment was challenged for being confirmed without a reply to the show cause notice, raising breach of natural justice. The Court noted that the impugned order was passed only because no reply had been filed, while the record also showed attachment of the bank account and full recovery of the arrears for the relevant year. The matter was remitted for fresh consideration on merits, with liberty to the petitioner to file a reply with supporting documents and with prior notice before the fresh order. The remand was made conditional: if the reply was not filed within the stipulated time, the impugned assessment order would stand confirmed.
Assessment was challenged for being confirmed without a reply to the show cause notice, raising breach of natural justice. The Court noted that the impugned order was passed only because no reply had been filed, while the record also showed attachment of the bank account and full recovery of the arrears for the relevant year. The matter was remitted for fresh consideration on merits, with liberty to the petitioner to file a reply with supporting documents and with prior notice before the fresh order. The remand was made conditional: if the reply was not filed within the stipulated time, the impugned assessment order would stand confirmed.
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