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...
Territorial jurisdiction in writ proceedings depends on where the cause of action arises, and a GST assessment challenge must be filed before the forum connected with the impugned order. Here, the assessment order was passed by the proper officer at Chandigarh, and the dispute stemmed from the return filed there, so no part of the cause of action arose within Patna HC's jurisdiction. The petitioner's lease of parking space at Patna was held insufficient to confer jurisdiction. The writ petition was therefore not maintainable, with liberty to approach the competent forum.
Territorial jurisdiction in writ proceedings depends on where the cause of action arises, and a GST assessment challenge must be filed before the forum connected with the impugned order. Here, the assessment order was passed by the proper officer at Chandigarh, and the dispute stemmed from the return filed there, so no part of the cause of action arose within Patna HC's jurisdiction. The petitioner's lease of parking space at Patna was held insufficient to confer jurisdiction. The writ petition was therefore not maintainable, with liberty to approach the competent forum.
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