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...
Availability of the GST Appellate Tribunal rendered the writ challenge unnecessary, as the Court noted that the Tribunal had been constituted, its procedural rules notified, and Members appointed. The petitioner was therefore relegated to the statutory appellate remedy, and the Court declined to examine the impugned orders on merits. An appeal was permitted to be filed within the period notified by the Central Government, with a direction that no limitation objection be raised if filed within that period. The amount already deposited under the interim order was treated as compliance with the statutory pre-deposit requirement, subject to production of the certified copy of the interim order and proof of deposit, and any appeal defects were to be cured within the stipulated time.
Availability of the GST Appellate Tribunal rendered the writ challenge unnecessary, as the Court noted that the Tribunal had been constituted, its procedural rules notified, and Members appointed. The petitioner was therefore relegated to the statutory appellate remedy, and the Court declined to examine the impugned orders on merits. An appeal was permitted to be filed within the period notified by the Central Government, with a direction that no limitation objection be raised if filed within that period. The amount already deposited under the interim order was treated as compliance with the statutory pre-deposit requirement, subject to production of the certified copy of the interim order and proof of deposit, and any appeal defects were to be cured within the stipulated time.
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