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...
In GST scrutiny, once ASMT-10 is issued and a reply is filed, the proceedings must proceed to ASMT-12 or to DRC-01A followed by DRC-01; ASMT-13 is confined to non-filers under Section 62, so its use after ASMT-10 and ASMT-11 was procedurally invalid. On that defect, the DRC-07 orders for one registration were set aside, treated as DRC-01 notices, and remitted for de novo adjudication, with the pendency period excluded for limitation. For the other registration, the inspection material justified invocation of the extended period under Section 74, and the writ petitions were dismissed because DRC-01A, DRC-01 and assessment orders were properly issued.
In GST scrutiny, once ASMT-10 is issued and a reply is filed, the proceedings must proceed to ASMT-12 or to DRC-01A followed by DRC-01; ASMT-13 is confined to non-filers under Section 62, so its use after ASMT-10 and ASMT-11 was procedurally invalid. On that defect, the DRC-07 orders for one registration were set aside, treated as DRC-01 notices, and remitted for de novo adjudication, with the pendency period excluded for limitation. For the other registration, the inspection material justified invocation of the extended period under Section 74, and the writ petitions were dismissed because DRC-01A, DRC-01 and assessment orders were properly issued.
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