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...
Cancellation of GST registration of petitioner - appeal barred by limitation or not - appeal was filed after a period of four months - Noting the significance of proper service of notice, the High Court emphasized the mandatory prerequisites for triggering the limitation period, including a finding on the mode of service and recording satisfaction regarding communication to the concerned party. - The Court observed deficiencies in the impugned order, specifically its failure to address the mode of service of the order and lack of satisfaction. - Setting aside the impugned order, the Court remitted the matter to the appellate authority for fresh adjudication.
Cancellation of GST registration of petitioner - appeal barred by limitation or not - appeal was filed after a period of four months - Noting the significance of proper service of notice, the High Court emphasized the mandatory prerequisites for triggering the limitation period, including a finding on the mode of service and recording satisfaction regarding communication to the concerned party. - The Court observed deficiencies in the impugned order, specifically its failure to address the mode of service of the order and lack of satisfaction. - Setting aside the impugned order, the Court remitted the matter to the appellate authority for fresh adjudication.
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