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...
Suspension of petitioner's Customs Broker License under Regulation 16 of the Customs Brokers Licensing Regulations (CBLR), 2018 - Extension of period of 90 days - Though, COVID 19 pandemic, did not abate and there was a 2nd wave till May-June, 2021, no notification has been brought to the attention of this Court that the time was further extended by the Central Board of Indirect Taxes, similar to the Notifications issued by the Central Board of Direct Taxes under the provisions of the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020 for the Purpose of Income Tax Act, 1961 - The HC held that, Proceedings have to therefore abate, since there was a failure in complying with the requirements of Regulation 17(5).
Suspension of petitioner's Customs Broker License under Regulation 16 of the Customs Brokers Licensing Regulations (CBLR), 2018 - Extension of period of 90 days - Though, COVID 19 pandemic, did not abate and there was a 2nd wave till May-June, 2021, no notification has been brought to the attention of this Court that the time was further extended by the Central Board of Indirect Taxes, similar to the Notifications issued by the Central Board of Direct Taxes under the provisions of the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020 for the Purpose of Income Tax Act, 1961 - The HC held that, Proceedings have to therefore abate, since there was a failure in complying with the requirements of Regulation 17(5).
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