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...
Use of AI-generated legal material in quasi-judicial orders requires independent verification, human oversight, and the issuing officer's own application of mind. Reliance on non-existent or irrelevant AI-generated precedents prompted an unconditional apology, and non-compliance with departmental safeguards was directed to be treated as contempt of court. GST registration cancellation proceedings were quashed because the authorities proposed to revise the challenged orders and issue a fresh notice. Fresh adjudication must consider the taxpayer's reply and defence and result in a reasoned order in accordance with law; the merits remain open.
Use of AI-generated legal material in quasi-judicial orders requires independent verification, human oversight, and the issuing officer's own application of mind. Reliance on non-existent or irrelevant AI-generated precedents prompted an unconditional apology, and non-compliance with departmental safeguards was directed to be treated as contempt of court. GST registration cancellation proceedings were quashed because the authorities proposed to revise the challenged orders and issue a fresh notice. Fresh adjudication must consider the taxpayer's reply and defence and result in a reasoned order in accordance with law; the merits remain open.
Note: It is a system-generated summary and is for quick reference only.