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...
Late fee is leviable for failure to furnish the annual return by the due date, not only for belated filing after eventual submission; on that construction, non-filing of Form GSTR-9 attracts liability under the late-fee provision up to the prescribed cap. Where no separate penalty is prescribed for failure to file the annual return, the general penalty provision may still be invoked, and the existence of late-fee liability does not bar that recourse. The High Court upheld both the late fee and the penalty and dismissed the writ petition.
Late fee is leviable for failure to furnish the annual return by the due date, not only for belated filing after eventual submission; on that construction, non-filing of Form GSTR-9 attracts liability under the late-fee provision up to the prescribed cap. Where no separate penalty is prescribed for failure to file the annual return, the general penalty provision may still be invoked, and the existence of late-fee liability does not bar that recourse. The High Court upheld both the late fee and the penalty and dismissed the writ petition.
Note: It is a system-generated summary and is for quick reference only.