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...
Section 174(2)(e) of the CGST Act saved investigation, inquiry, assessment, adjudication and other legal proceedings after omission of Chapter V of the Finance Act, 1994. The HC held that this saving clause preserved the authority to institute and continue service tax proceedings as if the earlier law had not been amended or repealed, so a show cause notice issued under the repealed service tax law remained valid. The writ challenge based on repeal was rejected, and the assessee was left to pursue adjudication independently in accordance with law.
Section 174(2)(e) of the CGST Act saved investigation, inquiry, assessment, adjudication and other legal proceedings after omission of Chapter V of the Finance Act, 1994. The HC held that this saving clause preserved the authority to institute and continue service tax proceedings as if the earlier law had not been amended or repealed, so a show cause notice issued under the repealed service tax law remained valid. The writ challenge based on repeal was rejected, and the assessee was left to pursue adjudication independently in accordance with law.
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