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...
Upload of the GST notice and adjudication order on the common portal constituted valid service under the statutory scheme; the HC rejected the claim that physical or postal service was additionally required. The petitioner had admitted that the notice was uploaded and did not place material particulars showing the actual date of knowledge, while the record also showed prior participation in the proceedings. On that basis, the plea of complete ignorance was not accepted, and the petitioner failed to justify bypassing the statutory remedy after expiry of the appellate period. The writ challenge to the GST demand was therefore dismissed as lacking merit.
Upload of the GST notice and adjudication order on the common portal constituted valid service under the statutory scheme; the HC rejected the claim that physical or postal service was additionally required. The petitioner had admitted that the notice was uploaded and did not place material particulars showing the actual date of knowledge, while the record also showed prior participation in the proceedings. On that basis, the plea of complete ignorance was not accepted, and the petitioner failed to justify bypassing the statutory remedy after expiry of the appellate period. The writ challenge to the GST demand was therefore dismissed as lacking merit.
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