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...
Corporate guarantee taxability under GST was remitted for fresh assessment because the assessing authority had not properly considered the petitioner's reliance on applicable GST circulars, the contention that only 1% of turnover was taxable, and the earlier Madras HC ruling cited in support. The Court held that these aspects required examination and that the assessment could not stand on the corporate guarantee issue alone. The impugned order was therefore set aside only to that limited extent, with directions for fresh orders after hearing the petitioner and considering supporting material; all other findings were left undisturbed.
Corporate guarantee taxability under GST was remitted for fresh assessment because the assessing authority had not properly considered the petitioner's reliance on applicable GST circulars, the contention that only 1% of turnover was taxable, and the earlier Madras HC ruling cited in support. The Court held that these aspects required examination and that the assessment could not stand on the corporate guarantee issue alone. The impugned order was therefore set aside only to that limited extent, with directions for fresh orders after hearing the petitioner and considering supporting material; all other findings were left undisturbed.
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