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...
Reasonable opportunity must be given before a fraud-based GST demand is confirmed where input tax credit has already been reversed and revenue interest is otherwise protected. The HC held that the petitioner could not be denied the chance to produce material documents to show genuine supply of goods and to challenge the invocation of Section 74. The impugned order was interfered with only to that limited extent, and the matter was remitted for fresh reconsideration after giving the petitioner a fair opportunity. No finding was returned on the merits of the underlying tax dispute.
Reasonable opportunity must be given before a fraud-based GST demand is confirmed where input tax credit has already been reversed and revenue interest is otherwise protected. The HC held that the petitioner could not be denied the chance to produce material documents to show genuine supply of goods and to challenge the invocation of Section 74. The impugned order was interfered with only to that limited extent, and the matter was remitted for fresh reconsideration after giving the petitioner a fair opportunity. No finding was returned on the merits of the underlying tax dispute.
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