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 considered a case involving the effect of a retrospective amendment in Section 50 of the CGST Act, 2017 by the Finance Act, 2021. The petition was dismissed due to the appellants' delay in approaching the court. The court noted that the appellate authority did not address the impact of the retrospective amendment in its previous order. As a legal issue was raised, the court allowed the appeal and writ petition, setting aside the appellate authority's order and remanding the matter for reconsideration in light of the retrospective amendment.
The High Court considered a case involving the effect of a retrospective amendment in Section 50 of the CGST Act, 2017 by the Finance Act, 2021. The petition was dismissed due to the appellants' delay in approaching the court. The court noted that the appellate authority did not address the impact of the retrospective amendment in its previous order. As a legal issue was raised, the court allowed the appeal and writ petition, setting aside the appellate authority's order and remanding the matter for reconsideration in light of the retrospective amendment.
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