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...
Section 129(3) of the CGST/KGST Act requires a proper officer to pass a penalty order within seven days of serving a detention notice for goods in transit. The use of "shall" is treated as mandatory because the provision governs coercive detention and seizure powers, even though no express consequence is specified for delay. A penalty order issued forty-seven days after notice was treated as beyond the prescribed limitation and without jurisdiction. The resulting penalty and appellate orders were set aside, with consequential release of the bank guarantee.
Section 129(3) of the CGST/KGST Act requires a proper officer to pass a penalty order within seven days of serving a detention notice for goods in transit. The use of "shall" is treated as mandatory because the provision governs coercive detention and seizure powers, even though no express consequence is specified for delay. A penalty order issued forty-seven days after notice was treated as beyond the prescribed limitation and without jurisdiction. The resulting penalty and appellate orders were set aside, with consequential release of the bank guarantee.
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