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...
Detention of goods in transit - GST registration of purchaser / petitioner had been cancelled - Petitioner has opted for composition scheme - The fact remains that if the petitioner is in compounding, the benefit of input tax credit cannot be availed, hence there cannot be any evasion of tax, if the registration of the petitioner was cancelled on 30.11.2018, the generation of e-way bill, which has not been disputed to be genuine, the seizure cannot be made - HC
Detention of goods in transit - GST registration of purchaser / petitioner had been cancelled - Petitioner has opted for composition scheme - The fact remains that if the petitioner is in compounding, the benefit of input tax credit cannot be availed, hence there cannot be any evasion of tax, if the registration of the petitioner was cancelled on 30.11.2018, the generation of e-way bill, which has not been disputed to be genuine, the seizure cannot be made - HC
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