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...
Validity of audit report u.s 65(6) of GST Act - the impugned audit report cannot be said to be after a reasonable opportunity. - The petition is allowed-in-part, quashing the impugned Audit Report - The petitioner is reserved liberty to file its response with the third respondent on or before 27.02.2023 and for the purposes of Section 65[6] of the KGST/CGST Act, the prescribed thirty days shall be computed from 27.02.2023. - HC
Validity of audit report u.s 65(6) of GST Act - the impugned audit report cannot be said to be after a reasonable opportunity. - The petition is allowed-in-part, quashing the impugned Audit Report - The petitioner is reserved liberty to file its response with the third respondent on or before 27.02.2023 and for the purposes of Section 65[6] of the KGST/CGST Act, the prescribed thirty days shall be computed from 27.02.2023. - HC
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