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 High Court addressed a case involving penalty for non-filing of annual return under the GST laws. The petitioner argued that notices were only uploaded on the GST portal without direct communication, violating natural justice. The petitioner, citing turnover below threshold, sought a chance to contest. Evidence of tax payment was presented. The Court noted lack of response to show cause notice led to tax confirmation. Orders were set aside pending verification of tax payment. Petitioner allowed two weeks to reply to notices. Petition disposed off, emphasizing the right to contest on merits.
The High Court addressed a case involving penalty for non-filing of annual return under the GST laws. The petitioner argued that notices were only uploaded on the GST portal without direct communication, violating natural justice. The petitioner, citing turnover below threshold, sought a chance to contest. Evidence of tax payment was presented. The Court noted lack of response to show cause notice led to tax confirmation. Orders were set aside pending verification of tax payment. Petitioner allowed two weeks to reply to notices. Petition disposed off, emphasizing the right to contest on merits.
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