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...
Section 73 of the CGST Act requires GST assessment and demand limitation to be determined separately for each financial year, with reference to the relevant annual return. A composite show cause notice covering multiple financial years improperly combines distinct tax periods, due dates, limitation periods, allegations and response opportunities. High Court precedent is binding within its territorial jurisdiction. The composite notice was quashed, while preserving the respondents' liberty to issue fresh notices separately in accordance with Section 73, subject to any other legal impediment.
Section 73 of the CGST Act requires GST assessment and demand limitation to be determined separately for each financial year, with reference to the relevant annual return. A composite show cause notice covering multiple financial years improperly combines distinct tax periods, due dates, limitation periods, allegations and response opportunities. High Court precedent is binding within its territorial jurisdiction. The composite notice was quashed, while preserving the respondents' liberty to issue fresh notices separately in accordance with Section 73, subject to any other legal impediment.
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