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 74 GST action was upheld because the show cause notice and assessment were based on a prima facie discrepancy between the seigniorage fee-linked quantity/value and the lower value disclosed in returns, amounting to alleged suppression of outward supply. The HC held that this was sufficient foundational material for invoking the extended period of limitation, and rejected the challenge that there was no basis for Section 74 proceedings. The natural justice objection also failed because intimation notices and show cause notices had been issued and replies were filed, leaving no procedural defect warranting writ interference. The writ petitions were dismissed, with liberty to pursue the statutory appeal.
Section 74 GST action was upheld because the show cause notice and assessment were based on a prima facie discrepancy between the seigniorage fee-linked quantity/value and the lower value disclosed in returns, amounting to alleged suppression of outward supply. The HC held that this was sufficient foundational material for invoking the extended period of limitation, and rejected the challenge that there was no basis for Section 74 proceedings. The natural justice objection also failed because intimation notices and show cause notices had been issued and replies were filed, leaving no procedural defect warranting writ interference. The writ petitions were dismissed, with liberty to pursue the statutory appeal.
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