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 challenge to an assessment order, noting a violation of natural justice principles due to lack of communication of show cause notice and order through means other than GST portal upload. Discrepancies between GSTR 3B and GSTR 2A were reconciled in annual return GSTR-9. Petitioner, though not participating in proceedings, reconciled disparities in the return. The court held that the petitioner should be given an opportunity to contest the tax demand. The impugned order was quashed, with a condition for the petitioner to remit 10% of disputed tax demand within two weeks for the petition to be allowed.
The High Court addressed a challenge to an assessment order, noting a violation of natural justice principles due to lack of communication of show cause notice and order through means other than GST portal upload. Discrepancies between GSTR 3B and GSTR 2A were reconciled in annual return GSTR-9. Petitioner, though not participating in proceedings, reconciled disparities in the return. The court held that the petitioner should be given an opportunity to contest the tax demand. The impugned order was quashed, with a condition for the petitioner to remit 10% of disputed tax demand within two weeks for the petition to be allowed.
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