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 SCN - validity of extension of outer time limit provided in the statute for issuance of notice under sub-Section (2) of Section 73 of the GST Act - The court considers the jurisdictional issue and the prima facie case made by the petitioner but does not stay the notice. The court orders that no final order shall be passed without the leave of the court.
Validity of SCN - validity of extension of outer time limit provided in the statute for issuance of notice under sub-Section (2) of Section 73 of the GST Act - The court considers the jurisdictional issue and the prima facie case made by the petitioner but does not stay the notice. The court orders that no final order shall be passed without the leave of the court.
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