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...
Petitioner availed fake input tax credit through bogus billing, generating fake sale invoices. Provisional attachment of movable properties in addition to immovable properties already attached was ordered u/s 83 to protect government revenue interest. Authority formed opinion based on material that petitioner's immovable properties were insufficient to cover likely demand exceeding Rs. 76 crore arising from fraudulent invoices and input tax credit utilization. No harassment found in provisional attachment of movable properties during pendency of investigation to safeguard revenue interest. Petition dismissed by High Court.
Petitioner availed fake input tax credit through bogus billing, generating fake sale invoices. Provisional attachment of movable properties in addition to immovable properties already attached was ordered u/s 83 to protect government revenue interest. Authority formed opinion based on material that petitioner's immovable properties were insufficient to cover likely demand exceeding Rs. 76 crore arising from fraudulent invoices and input tax credit utilization. No harassment found in provisional attachment of movable properties during pendency of investigation to safeguard revenue interest. Petition dismissed by High Court.
Note: It is a system-generated summary and is for quick reference only.