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...
Allegations of bogus or paper transactions in the supply chain can support cancellation of GST registration even while return scrutiny is pending, because the two proceedings may run separately and the pendency of scrutiny creates no legal bar. Where the cancellation notice turns on disputed facts, writ jurisdiction is not the proper forum for fact-finding, and the controversy must be tested on evidence before the statutory authority. The High Court therefore declined interference under Article 226, found no adverse meaning could be attached merely to the reference to pending scrutiny, and left the assessee to pursue the statutory appeal on merits.
Allegations of bogus or paper transactions in the supply chain can support cancellation of GST registration even while return scrutiny is pending, because the two proceedings may run separately and the pendency of scrutiny creates no legal bar. Where the cancellation notice turns on disputed facts, writ jurisdiction is not the proper forum for fact-finding, and the controversy must be tested on evidence before the statutory authority. The High Court therefore declined interference under Article 226, found no adverse meaning could be attached merely to the reference to pending scrutiny, and left the assessee to pursue the statutory appeal on merits.
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