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 - Detention of petitioner's goods - E-Way Bill does not reflect the name of the consignee but merely mentions the petitioner’s GSTIN number - it is apparent that neither the show cause notice nor the order of demand clearly sets out the reason for imposing the tax liability as well as penalty. - It would be apposite to remand the matter to the concerned GST officer to decide afresh after giving the petitioner full opportunity to address the allegation against him - HC
Levy of penalty - Detention of petitioner's goods - E-Way Bill does not reflect the name of the consignee but merely mentions the petitioner’s GSTIN number - it is apparent that neither the show cause notice nor the order of demand clearly sets out the reason for imposing the tax liability as well as penalty. - It would be apposite to remand the matter to the concerned GST officer to decide afresh after giving the petitioner full opportunity to address the allegation against him - HC
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