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...
Collateral challenge to a CGST adjudication order through an interlocutory application in a pending writ petition was not maintainable because the earlier AGST notice challenge had no connection with the subsequent CGST proceedings. No interim restraint covered the adjudication, and no jurisdictional error by the Proper Officer was established; the writ challenge became infructuous and the interlocutory challenge was misconceived. Bona fide and diligent pursuit of the wrong writ remedy justified allowing recourse to the statutory appellate remedy despite expiry of limitation. Petitioners received liberty to file an appeal under the CGST Act within 30 days, to be considered on merits without limitation objection; prior interim protection was vacated.
Collateral challenge to a CGST adjudication order through an interlocutory application in a pending writ petition was not maintainable because the earlier AGST notice challenge had no connection with the subsequent CGST proceedings. No interim restraint covered the adjudication, and no jurisdictional error by the Proper Officer was established; the writ challenge became infructuous and the interlocutory challenge was misconceived. Bona fide and diligent pursuit of the wrong writ remedy justified allowing recourse to the statutory appellate remedy despite expiry of limitation. Petitioners received liberty to file an appeal under the CGST Act within 30 days, to be considered on merits without limitation objection; prior interim protection was vacated.
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