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...
GST show cause and demand proceedings initiated against a deceased sole proprietor, after death and cancellation of the proprietorship registration, cannot be sustained. The legal heir was unconnected with the business and unaware of proceedings conducted through the GST portal. The High Court quashed the notices and consequential demand order, while preserving the authority's right to commence proper proceedings in accordance with law against the legal heir for any outstanding demand.
GST show cause and demand proceedings initiated against a deceased sole proprietor, after death and cancellation of the proprietorship registration, cannot be sustained. The legal heir was unconnected with the business and unaware of proceedings conducted through the GST portal. The High Court quashed the notices and consequential demand order, while preserving the authority's right to commence proper proceedings in accordance with law against the legal heir for any outstanding demand.
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