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...
Profiteering - supply of “American Tourister Sky Tracer HL Blue 68 cm Hard Trolley” - allegation that the Respondent did not reduce the selling price of the above product when the GST rate was reduced and thus, the benefit of reduction in the GST rate was not passed on to the recipients by way of commensurate reduction in its price - contravention of section 171 of CGST Act - Since, the recipients in this case are not identifiable, the above Respondent is directed to deposit the amount of profiteering of ₹ 25,73,82,482/- along with interest in the CWFs of the Central and the concerned State Governments.
Profiteering - supply of “American Tourister Sky Tracer HL Blue 68 cm Hard Trolley” - allegation that the Respondent did not reduce the selling price of the above product when the GST rate was reduced and thus, the benefit of reduction in the GST rate was not passed on to the recipients by way of commensurate reduction in its price - contravention of section 171 of CGST Act - Since, the recipients in this case are not identifiable, the above Respondent is directed to deposit the amount of profiteering of ₹ 25,73,82,482/- along with interest in the CWFs of the Central and the concerned State Governments.
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