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...
The audit wing of the State GST Authority directed to keep in abeyance all proceedings related to discrepancy note no. 3, including the show cause notice dated 29.12.2023. This decision was made because the same discrepancy is already under adjudication by the CGST Authority, following a show cause notice dated 28.03.2023. The court ordered that the State GST Authority's audit wing should not proceed with their actions until the adjudication order by the CGST Authority is passed. - HC
The audit wing of the State GST Authority directed to keep in abeyance all proceedings related to discrepancy note no. 3, including the show cause notice dated 29.12.2023. This decision was made because the same discrepancy is already under adjudication by the CGST Authority, following a show cause notice dated 28.03.2023. The court ordered that the State GST Authority's audit wing should not proceed with their actions until the adjudication order by the CGST Authority is passed. - HC
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