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...
A writ challenge to a GST show cause notice was not entertained where the petitioner had not shown that any objection to the alleged defect in FORM GST DRC-01 had first been raised before the competent authority. The record also contained a signed notice issued by the Deputy Commissioner, which undermined the unsigned-notice objection. The court therefore declined to examine the grievance in writ jurisdiction and left the petitioner free to point out any defect before the authority concerned.
A writ challenge to a GST show cause notice was not entertained where the petitioner had not shown that any objection to the alleged defect in FORM GST DRC-01 had first been raised before the competent authority. The record also contained a signed notice issued by the Deputy Commissioner, which undermined the unsigned-notice objection. The court therefore declined to examine the grievance in writ jurisdiction and left the petitioner free to point out any defect before the authority concerned.
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