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...
GST assessment orders concerning short payment of tax and alleged non-payment on seigniorage fees under reverse charge mechanism were remitted for fresh adjudication. On the short-reported turnover issue, the impugned orders were treated as an addendum to the show cause notices, and the taxpayer was required to deposit 25% of the disputed tax and file separate replies with supporting documents before fresh merits-based orders were passed. On the seigniorage-fee issue, substantive taxability was not decided; instead, the matter was deferred, a 10% deposit and replies were required, and separate orders were directed only after the Supreme Court resolves the reverse charge taxability question, leaving that controversy open.
GST assessment orders concerning short payment of tax and alleged non-payment on seigniorage fees under reverse charge mechanism were remitted for fresh adjudication. On the short-reported turnover issue, the impugned orders were treated as an addendum to the show cause notices, and the taxpayer was required to deposit 25% of the disputed tax and file separate replies with supporting documents before fresh merits-based orders were passed. On the seigniorage-fee issue, substantive taxability was not decided; instead, the matter was deferred, a 10% deposit and replies were required, and separate orders were directed only after the Supreme Court resolves the reverse charge taxability question, leaving that controversy open.
Note: It is a system-generated summary and is for quick reference only.