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...
Adjudication of SCN after 17 years - The High Court ruled that the belated adjudication of the show cause notice rendered it arbitrary and illegal. Citing the principle established in the case of Coventry Estates Pvt. Ltd. vs. The Joint Commissioner, CGST and Central Excise and Anr. 2023, the Court held that such a prolonged delay in adjudication violates legal principles.
Adjudication of SCN after 17 years - The High Court ruled that the belated adjudication of the show cause notice rendered it arbitrary and illegal. Citing the principle established in the case of Coventry Estates Pvt. Ltd. vs. The Joint Commissioner, CGST and Central Excise and Anr. 2023, the Court held that such a prolonged delay in adjudication violates legal principles.
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