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 u/s GST ASMT-10 due to non-submission of required documents. The assessing officer rejected the petitioner's reply citing lack of reconciliation statements and incomplete submission of relevant invoices. The Court found the rejection unsustainable as the petitioner's reply in Form ASMT-10 was sufficient. However, the petitioner failed to provide all necessary invoices to justify excluding certain expenses from taxable turnover. The Court quashed the order and remanded the matter for reconsideration, allowing the petitioner to submit additional documents to clarify the taxable turnover disparity. The petition was disposed of through remand.
The High Court addressed a challenge to an assessment order u/s GST ASMT-10 due to non-submission of required documents. The assessing officer rejected the petitioner's reply citing lack of reconciliation statements and incomplete submission of relevant invoices. The Court found the rejection unsustainable as the petitioner's reply in Form ASMT-10 was sufficient. However, the petitioner failed to provide all necessary invoices to justify excluding certain expenses from taxable turnover. The Court quashed the order and remanded the matter for reconsideration, allowing the petitioner to submit additional documents to clarify the taxable turnover disparity. The petition was disposed of through remand.
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