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...
Eligibility for Composition scheme - ice-cream - limited grievance of the petitioners is that the ‘Ice Cream’ has been placed on par with Pan Masala and Tobacco - The High Court scrutinized the decision of the GST Council and found it lacking in adequate reasoning. It emphasized the importance of reasonable classification in taxation laws, citing constitutional principles and judicial precedents. Ice Cream, being a widely consumed item, cannot be arbitrarily placed in the same category as luxury goods without proper justification. Consequently, the High Court directed the GST Council to reconsider its decision regarding the exclusion of Small-Scale Ice Cream Manufacturers from the composition scheme. The Court expected the Council to make this decision within a reasonable timeframe, preferably three months.
Eligibility for Composition scheme - ice-cream - limited grievance of the petitioners is that the ‘Ice Cream’ has been placed on par with Pan Masala and Tobacco - The High Court scrutinized the decision of the GST Council and found it lacking in adequate reasoning. It emphasized the importance of reasonable classification in taxation laws, citing constitutional principles and judicial precedents. Ice Cream, being a widely consumed item, cannot be arbitrarily placed in the same category as luxury goods without proper justification. Consequently, the High Court directed the GST Council to reconsider its decision regarding the exclusion of Small-Scale Ice Cream Manufacturers from the composition scheme. The Court expected the Council to make this decision within a reasonable timeframe, preferably three months.
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