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...
Parallel GST proceedings are barred only where Central and State proceedings concern the same subject matter. Common input tax credit issues or the same financial year alone do not establish that condition; the respective show-cause notices, allegations, transactions, computations, evidentiary material and proposed liabilities require comparison. Where an effective statutory appeal is available and the objection requires examination of the underlying record, writ jurisdiction need not be exercised. Failure to raise the objection in a written reply and participation in adjudication may be relevant to discretionary writ relief, without deciding the objection on its merits. The parallel-proceedings issue and demand challenge remain available for appellate consideration.
Parallel GST proceedings are barred only where Central and State proceedings concern the same subject matter. Common input tax credit issues or the same financial year alone do not establish that condition; the respective show-cause notices, allegations, transactions, computations, evidentiary material and proposed liabilities require comparison. Where an effective statutory appeal is available and the objection requires examination of the underlying record, writ jurisdiction need not be exercised. Failure to raise the objection in a written reply and participation in adjudication may be relevant to discretionary writ relief, without deciding the objection on its merits. The parallel-proceedings issue and demand challenge remain available for appellate consideration.
Note: It is a system-generated summary and is for quick reference only.