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...
Seeking provisional release of goods and conveyance - suspicious transaction involving fake input tax credit - Power and jurisdiction u/s 129 versus u/s 130 - Delinking the two provisions - The respondent authorities are directed to provisionally release the goods and conveyance subject to the condition that the writ applicant shall deposit the total amount payable, including penalty, as determined by the respondent authority within period of one week from date of receipt of this order and upon realisation of such amount, the respondent authority shall forthwith release such goods and conveyance- HC
Seeking provisional release of goods and conveyance - suspicious transaction involving fake input tax credit - Power and jurisdiction u/s 129 versus u/s 130 - Delinking the two provisions - The respondent authorities are directed to provisionally release the goods and conveyance subject to the condition that the writ applicant shall deposit the total amount payable, including penalty, as determined by the respondent authority within period of one week from date of receipt of this order and upon realisation of such amount, the respondent authority shall forthwith release such goods and conveyance- HC
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