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 Madras High Court found a violation of natural justice as notices were only uploaded on the GST portal without direct communication to the petitioner. The tax proposal related to discrepancies in GSTR returns and Input Tax Credit (ITC). The court set aside the order and remanded the matter for reconsideration, requiring the petitioner to remit 10% of the disputed tax demand within two weeks. The petition was disposed of by way of remand, granting the petitioner an opportunity to contest the tax demand.
The Madras High Court found a violation of natural justice as notices were only uploaded on the GST portal without direct communication to the petitioner. The tax proposal related to discrepancies in GSTR returns and Input Tax Credit (ITC). The court set aside the order and remanded the matter for reconsideration, requiring the petitioner to remit 10% of the disputed tax demand within two weeks. The petition was disposed of by way of remand, granting the petitioner an opportunity to contest the tax demand.
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