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...
Duplicate GST adjudication on the same issues and assessment period is unsustainable where Central GST authorities have already issued an order and that order remains under appeal. The subsequent State GST assessment and rectification orders addressed identical issues for the identical period, thereby duplicating the earlier Central GST adjudication. The State GST orders were quashed, and the writ petition was allowed.
Duplicate GST adjudication on the same issues and assessment period is unsustainable where Central GST authorities have already issued an order and that order remains under appeal. The subsequent State GST assessment and rectification orders addressed identical issues for the identical period, thereby duplicating the earlier Central GST adjudication. The State GST orders were quashed, and the writ petition was allowed.
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