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...
Monetary limits continue to govern departmental filing of appeals, applications and special leave petitions under the UPGST framework: GSTAT matters below Rs. 20,00,000, High Court matters below Rs. 1,00,00,000 and Supreme Court matters below Rs. 2,00,00,000 are ordinarily not to be pursued. The limits do not apply where a provision, rule, regulation, order, notification, direction or circular is treated as unconstitutional, or where the dispute concerns valuation, classification, refunds, place of supply, recurring interpretative issues, adverse costs or observations, or any matter the Commissioner considers necessary in the interest of justice or revenue. Zonal Law Committees are to review first appellate orders, meet at least twice monthly, record minutes and identify cases for appeal or best-practice circulation.
Monetary limits continue to govern departmental filing of appeals, applications and special leave petitions under the UPGST framework: GSTAT matters below Rs. 20,00,000, High Court matters below Rs. 1,00,00,000 and Supreme Court matters below Rs. 2,00,00,000 are ordinarily not to be pursued. The limits do not apply where a provision, rule, regulation, order, notification, direction or circular is treated as unconstitutional, or where the dispute concerns valuation, classification, refunds, place of supply, recurring interpretative issues, adverse costs or observations, or any matter the Commissioner considers necessary in the interest of justice or revenue. Zonal Law Committees are to review first appellate orders, meet at least twice monthly, record minutes and identify cases for appeal or best-practice circulation.
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