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...
A writ challenge to a show-cause notice was treated as premature because the notice only proposed action and the petitioner could still file objections in the statutory process; the Court therefore declined to entertain the petition, allowed a further reply to the corrigendum, and directed disposal by a reasoned and speaking order. On jurisdiction, the Court held that the CGST Assistant/Deputy Commissioner was vested with authority under the relevant rules, and a differing rubber-stamp description below the signature did not negate that competence. The jurisdictional objection was rejected.
A writ challenge to a show-cause notice was treated as premature because the notice only proposed action and the petitioner could still file objections in the statutory process; the Court therefore declined to entertain the petition, allowed a further reply to the corrigendum, and directed disposal by a reasoned and speaking order. On jurisdiction, the Court held that the CGST Assistant/Deputy Commissioner was vested with authority under the relevant rules, and a differing rubber-stamp description below the signature did not negate that competence. The jurisdictional objection was rejected.
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