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...
Garnishee notice - the issuance of Garnishee notice dated 25.02.2022 are in violation of principles of natural justice and the procedure prescribed under the JGST Act, the summary of show cause notice contained in GST DRC-01 is quashed; the adjudication order dated 1st November 2021 is quashed; the summary of the order and demand notice contained in GST DRC-07 dated 01.11.2021 (Annexure-6) and also Garnishee notice dated 25.02.2022 are also quashed. - HC
Garnishee notice - the issuance of Garnishee notice dated 25.02.2022 are in violation of principles of natural justice and the procedure prescribed under the JGST Act, the summary of show cause notice contained in GST DRC-01 is quashed; the adjudication order dated 1st November 2021 is quashed; the summary of the order and demand notice contained in GST DRC-07 dated 01.11.2021 (Annexure-6) and also Garnishee notice dated 25.02.2022 are also quashed. - HC
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