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...
Petition dismissed due to time limitation. Petitioners granted liberty to approach Appellate Commissioner u/s 107 of GST Act, subject to depositing 25% of disputed tax, with 10% being mandatory requirement u/s 107 and additional 15% for approaching court after expiry of limitation period. Petitioners directed to deposit 25% of disputed tax from Electronic Cash Register within 30 days from receipt of order. Petition disposed of.
Petition dismissed due to time limitation. Petitioners granted liberty to approach Appellate Commissioner u/s 107 of GST Act, subject to depositing 25% of disputed tax, with 10% being mandatory requirement u/s 107 and additional 15% for approaching court after expiry of limitation period. Petitioners directed to deposit 25% of disputed tax from Electronic Cash Register within 30 days from receipt of order. Petition disposed of.
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