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 Conclusion of proceedings u/s 73 of the Central Good and Service Tax Act 2017 without considering the reply filed by the petitioner - The court noted that the impugned order did not adequately address the petitioner's response. Despite the petitioner's detailed explanation, the order merely stated that the reply was not comprehensive and failed to consider the merits of the petitioner's explanation. - Consequently, HC set aside the impugned order and remitted the matter to the proper officer for re-adjudication.
Validity of Conclusion of proceedings u/s 73 of the Central Good and Service Tax Act 2017 without considering the reply filed by the petitioner - The court noted that the impugned order did not adequately address the petitioner's response. Despite the petitioner's detailed explanation, the order merely stated that the reply was not comprehensive and failed to consider the merits of the petitioner's explanation. - Consequently, HC set aside the impugned order and remitted the matter to the proper officer for re-adjudication.
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