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...
A show cause notice issued in disregard of a binding and unchallenged advance ruling was treated as non-est because the ruling had attained finality between the parties and remained operative under the CGST framework. The Court held that, where the invalidity of the notice was apparent on the face of the record, the petitioner was not required to first reply to the notice or pursue the statutory remedy. It therefore exercised writ jurisdiction under Article 226 and quashed the notice as lacking foundation.
A show cause notice issued in disregard of a binding and unchallenged advance ruling was treated as non-est because the ruling had attained finality between the parties and remained operative under the CGST framework. The Court held that, where the invalidity of the notice was apparent on the face of the record, the petitioner was not required to first reply to the notice or pursue the statutory remedy. It therefore exercised writ jurisdiction under Article 226 and quashed the notice as lacking foundation.
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