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 portal-based adjudication is intended to operate primarily through the Common Portal, so a noticee should not be required to adopt a hybrid process by filing supplementary replies only offline during personal hearing. The text states that where a further reply was attempted but blocked by portal limitations, the absence of that material from the record created a procedural defect and raised natural justice concerns. It further notes that the authority should have a request-based facility for online filing of additional replies, subject to control, and that the matter was therefore sent back for fresh consideration rather than leaving the party to the appellate route.
GST portal-based adjudication is intended to operate primarily through the Common Portal, so a noticee should not be required to adopt a hybrid process by filing supplementary replies only offline during personal hearing. The text states that where a further reply was attempted but blocked by portal limitations, the absence of that material from the record created a procedural defect and raised natural justice concerns. It further notes that the authority should have a request-based facility for online filing of additional replies, subject to control, and that the matter was therefore sent back for fresh consideration rather than leaving the party to the appellate route.
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