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...
Jurisdiction to issue show cause notice (SCN) for levy of interest and penalty was challenged. Court held that writ petitions challenging impugned orders under Article 226 of Constitution lack merit. Petitioner must file statutory appeal u/s 107 of TNGST Act, 2017. Writ petitions dismissed with liberty to file statutory appeal within 30 days from receipt of order. Pre-deposit requirement waived if petitioner paid 10% or more of tax for respective assessment years during inspection.
Jurisdiction to issue show cause notice (SCN) for levy of interest and penalty was challenged. Court held that writ petitions challenging impugned orders under Article 226 of Constitution lack merit. Petitioner must file statutory appeal u/s 107 of TNGST Act, 2017. Writ petitions dismissed with liberty to file statutory appeal within 30 days from receipt of order. Pre-deposit requirement waived if petitioner paid 10% or more of tax for respective assessment years during inspection.
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