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 assessment orders due to a mismatch in returns filed by the petitioner in GSTR 01 and GSTR 3B. The court found a violation of natural justice principles. The petitioner's attempt to absolve liability incurred by their deceased mother was rejected u/s 93 of the TNGST Act, 2017. The court quashed the impugned orders as they were issued post the mother's demise, remanding the case for fresh orders. The petitioner must deposit 10% of disputed tax for the remand process. The petition was allowed for remand.
The High Court addressed a challenge to assessment orders due to a mismatch in returns filed by the petitioner in GSTR 01 and GSTR 3B. The court found a violation of natural justice principles. The petitioner's attempt to absolve liability incurred by their deceased mother was rejected u/s 93 of the TNGST Act, 2017. The court quashed the impugned orders as they were issued post the mother's demise, remanding the case for fresh orders. The petitioner must deposit 10% of disputed tax for the remand process. The petition was allowed for remand.
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