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...
Belated filing of a GST return after a best judgment assessment under Section 62, together with payment of tax, interest and late fee, is treated as resulting in deemed withdrawal of the assessment order. The note records that once the return for the relevant period was filed and the statutory dues were discharged, recovery under the assessment order could not continue. It follows the cited High Court view that subsequent compliance cures the basis for pursuing recovery under the best judgment assessment.
Belated filing of a GST return after a best judgment assessment under Section 62, together with payment of tax, interest and late fee, is treated as resulting in deemed withdrawal of the assessment order. The note records that once the return for the relevant period was filed and the statutory dues were discharged, recovery under the assessment order could not continue. It follows the cited High Court view that subsequent compliance cures the basis for pursuing recovery under the best judgment assessment.
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