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...
Interference with a show cause notice is unwarranted unless it is ex facie without jurisdiction. Here, the GST dispute over an offshore construction contract turned on factual questions, including local procurement, shipments from the India office, and consolidation of Mauritius site accounts in the Indian company's financials. Those features had a bearing on the territorial applicability of GST, so the notice was not patently without jurisdiction and could not be quashed in writ proceedings as premature. The cited advance-ruling decision was distinguished because it did not arise from a writ challenge to a notice on disputed facts.
Interference with a show cause notice is unwarranted unless it is ex facie without jurisdiction. Here, the GST dispute over an offshore construction contract turned on factual questions, including local procurement, shipments from the India office, and consolidation of Mauritius site accounts in the Indian company's financials. Those features had a bearing on the territorial applicability of GST, so the notice was not patently without jurisdiction and could not be quashed in writ proceedings as premature. The cited advance-ruling decision was distinguished because it did not arise from a writ challenge to a notice on disputed facts.
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