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 under the GST regime was held vitiated because it did not bear a Document Identification Number, following the Court's earlier view that absence of a DIN invalidates the order. The order was therefore set aside and the matter remanded for fresh assessment after hearing the taxpayer. On the delayed writ challenge and disputed portal service, the Court did not finally resolve the service controversy but held that petitions attacking assessment orders with patent irregularities could be entertained on terms. Relief was made conditional on deposit of 20% of the disputed tax, with the period of writ pendency excluded for limitation and liberty preserved to raise all contentions before the Assessing Officer.
An assessment order under the GST regime was held vitiated because it did not bear a Document Identification Number, following the Court's earlier view that absence of a DIN invalidates the order. The order was therefore set aside and the matter remanded for fresh assessment after hearing the taxpayer. On the delayed writ challenge and disputed portal service, the Court did not finally resolve the service controversy but held that petitions attacking assessment orders with patent irregularities could be entertained on terms. Relief was made conditional on deposit of 20% of the disputed tax, with the period of writ pendency excluded for limitation and liberty preserved to raise all contentions before the Assessing Officer.
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