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...
Dismissal of contempt petition - The appellant filed a contempt petition alleging non-compliance with the High Court's order. However, the contempt bench dismissed the petition, stating that there was no provision under the GST Act for deciding the representation. - The court, independent of the contempt bench's observation, found that no contempt was made out due to the resolution of the representation by the competent authority. As the appellant's remedy was to challenge the order, the contempt petition was dismissed with liberty for the appellant to pursue further legal recourse.
Dismissal of contempt petition - The appellant filed a contempt petition alleging non-compliance with the High Court's order. However, the contempt bench dismissed the petition, stating that there was no provision under the GST Act for deciding the representation. - The court, independent of the contempt bench's observation, found that no contempt was made out due to the resolution of the representation by the competent authority. As the appellant's remedy was to challenge the order, the contempt petition was dismissed with liberty for the appellant to pursue further legal recourse.
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