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...
Demand under GST based solely on FORM 26AS entries could not be sustained where the sale deeds, if examined, indicated a prima facie sale of immovable property outside the GST levy. The HC found that the assessment proceeded on an assumed failure to produce the deeds, but once the copies of the sale deeds and corresponding FORM 26AS were considered, the underlying transaction required proper scrutiny. The impugned orders were quashed and the matter was remitted for fresh adjudication after notice.
Demand under GST based solely on FORM 26AS entries could not be sustained where the sale deeds, if examined, indicated a prima facie sale of immovable property outside the GST levy. The HC found that the assessment proceeded on an assumed failure to produce the deeds, but once the copies of the sale deeds and corresponding FORM 26AS were considered, the underlying transaction required proper scrutiny. The impugned orders were quashed and the matter was remitted for fresh adjudication after notice.
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