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...
Demand of GST - Validity of assessment orders - The petitioner contended that they provided all relevant documents, including those related to land transactions, during the assessment process. They argued that project details were submitted during rectification proceedings. - After examining the evidence and submissions, the court noted that the assessing officer had considered the petitioner's documents and entered findings based on such evidence. The court concluded that a reasonable opportunity was provided to the petitioner, and the assessment orders were not a result of non-application of mind. Therefore, the court found no grounds for interference in its discretionary jurisdiction.
Demand of GST - Validity of assessment orders - The petitioner contended that they provided all relevant documents, including those related to land transactions, during the assessment process. They argued that project details were submitted during rectification proceedings. - After examining the evidence and submissions, the court noted that the assessing officer had considered the petitioner's documents and entered findings based on such evidence. The court concluded that a reasonable opportunity was provided to the petitioner, and the assessment orders were not a result of non-application of mind. Therefore, the court found no grounds for interference in its discretionary jurisdiction.
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