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...
Writ jurisdiction was not entertained to challenge GST proceedings after the statutory appeal period had expired, because the petitioner had replied to the show cause notice and been heard, so jurisdictional error and breach of natural justice were not established. The High Court held that Article 226 cannot be used to bypass a special appellate scheme with a limited condonable period, especially in tax matters where diligence is required. In the absence of a proper explanation for delay or any patent illegality, the petition was dismissed, with liberty to proceed in accordance with law and without affecting any future appeal.
Writ jurisdiction was not entertained to challenge GST proceedings after the statutory appeal period had expired, because the petitioner had replied to the show cause notice and been heard, so jurisdictional error and breach of natural justice were not established. The High Court held that Article 226 cannot be used to bypass a special appellate scheme with a limited condonable period, especially in tax matters where diligence is required. In the absence of a proper explanation for delay or any patent illegality, the petition was dismissed, with liberty to proceed in accordance with law and without affecting any future appeal.
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