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...
Parallel GST adjudication on the same subject matter cannot continue once proceedings have been initiated by one authority, and Central and State authorities must coordinate to ermine which authority will proceed so the assessee is not exposed to duplicate adjudication for the same period and contravention. The Court also permitted the taxpayer to file fresh responses to the notices and directed the competent authority to consider the replies and supporting documents, hear the taxpayer, and pass a speaking and reasoned order in accordance with law. The constitutional challenge was not pressed, and the merits of the input tax credit claim were left open.
Parallel GST adjudication on the same subject matter cannot continue once proceedings have been initiated by one authority, and Central and State authorities must coordinate to ermine which authority will proceed so the assessee is not exposed to duplicate adjudication for the same period and contravention. The Court also permitted the taxpayer to file fresh responses to the notices and directed the competent authority to consider the replies and supporting documents, hear the taxpayer, and pass a speaking and reasoned order in accordance with law. The constitutional challenge was not pressed, and the merits of the input tax credit claim were left open.
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