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...
The Madhya Pradesh High Court directed the Respondent to release the original documents seized from the Petitioner's premises within 30 days of issuing the show cause notice, as per u/s 67(3) of the CGST Act and u/r 27 of the Central Excise Rules 2017. The Petitioner is entitled to both certified copies of relied documents and original copies of non-relied documents for a fair defense. The court emphasized the Petitioner's right to cross-examine witnesses relied upon in the show cause notices to ensure a fair hearing and adherence to principles of natural justice. The Respondents were ordered to provide all original seized documents to the Petitioner for preparing a reply, thereby allowing the petition.
The Madhya Pradesh High Court directed the Respondent to release the original documents seized from the Petitioner's premises within 30 days of issuing the show cause notice, as per u/s 67(3) of the CGST Act and u/r 27 of the Central Excise Rules 2017. The Petitioner is entitled to both certified copies of relied documents and original copies of non-relied documents for a fair defense. The court emphasized the Petitioner's right to cross-examine witnesses relied upon in the show cause notices to ensure a fair hearing and adherence to principles of natural justice. The Respondents were ordered to provide all original seized documents to the Petitioner for preparing a reply, thereby allowing the petition.
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