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...
Levy of penalty u/s 129(3) of the CGST Act, 2017 - petitioner has generated E-way bill by declaring the consignee as its additional place of business - intent to evade tax, present or not - Considering the fact that there is only a technical breach committed by the petitioner and there is no intention to evade tax, the impugned order is quashed and this writ petition is allowed by directing the respondent to release the vehicle and the consignment to the petitioner, if the same has not been released already. - HC
Levy of penalty u/s 129(3) of the CGST Act, 2017 - petitioner has generated E-way bill by declaring the consignee as its additional place of business - intent to evade tax, present or not - Considering the fact that there is only a technical breach committed by the petitioner and there is no intention to evade tax, the impugned order is quashed and this writ petition is allowed by directing the respondent to release the vehicle and the consignment to the petitioner, if the same has not been released already. - HC
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