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 demand of GST - For assessment year 2017-2018 - Notice in Form ASMT-10 issued for discrepancies found in returns - proceedings initiated pursuant to notice in Form ASMT-10, dropped by issuing an order in Form ASMT-12 - demand towards IGST, SGST and CGST - whether the same demand was resurrected - The court finds that the impugned assessment order confirms demands for the same assessment period and amounts, with the addition of interest and penalty. Given the previous conclusion that no further action was required, the continuation of proceedings leading to the impugned assessment order is deemed unsustainable.
Validity of demand of GST - For assessment year 2017-2018 - Notice in Form ASMT-10 issued for discrepancies found in returns - proceedings initiated pursuant to notice in Form ASMT-10, dropped by issuing an order in Form ASMT-12 - demand towards IGST, SGST and CGST - whether the same demand was resurrected - The court finds that the impugned assessment order confirms demands for the same assessment period and amounts, with the addition of interest and penalty. Given the previous conclusion that no further action was required, the continuation of proceedings leading to the impugned assessment order is deemed unsustainable.
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