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...
Following constitution of the GST Appellate Tribunal, the appellate remedy is available for challenging the impugned orders. The writ petition was disposed of without examining the orders' validity, with permission to file an appeal before the Tribunal by June 30, 2026. The appeal must be entertained without objection based on limitation, but remains subject to the specified mandatory pre-deposit requirements and removal of defects. The operative effect is that access to the Tribunal is preserved within the permitted timeframe, while compliance with pre-deposit and filing-defect directions remains necessary for entertainment of the appeal.
Following constitution of the GST Appellate Tribunal, the appellate remedy is available for challenging the impugned orders. The writ petition was disposed of without examining the orders' validity, with permission to file an appeal before the Tribunal by June 30, 2026. The appeal must be entertained without objection based on limitation, but remains subject to the specified mandatory pre-deposit requirements and removal of defects. The operative effect is that access to the Tribunal is preserved within the permitted timeframe, while compliance with pre-deposit and filing-defect directions remains necessary for entertainment of the appeal.
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