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...
Transitional Credit - Revision of return on MVAT for June 2017 - the order should be self-speaking. It cannot be that the Authority passes an order without reasons, and then arguments are advanced in a writ jurisdiction at the first instance. Furthermore, the Petitioner before us is not the one who is delaying the payment of taxes. Remand is also necessary to highlight the need to give a reasoned order. The learned Counsel for the parties jointly state that the exercise of power under section 25 of the MVAT Act of 2002 in respect of the order in question would be within the period of limitation. - Matter restored back - HC
Transitional Credit - Revision of return on MVAT for June 2017 - the order should be self-speaking. It cannot be that the Authority passes an order without reasons, and then arguments are advanced in a writ jurisdiction at the first instance. Furthermore, the Petitioner before us is not the one who is delaying the payment of taxes. Remand is also necessary to highlight the need to give a reasoned order. The learned Counsel for the parties jointly state that the exercise of power under section 25 of the MVAT Act of 2002 in respect of the order in question would be within the period of limitation. - Matter restored back - HC
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