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...
Challenge to assessment order - time limitation. It is not required to dilate on taxability under GST regime from 01.07.2017. Matter requires consideration on merits. Prayer for quashing cannot be considered. However, balancing interests, impugned orders set aside by remitting cases to pass fresh orders, subject to depositing 10% of disputed tax within 30 days. Petition disposed by way of remand.
Challenge to assessment order - time limitation. It is not required to dilate on taxability under GST regime from 01.07.2017. Matter requires consideration on merits. Prayer for quashing cannot be considered. However, balancing interests, impugned orders set aside by remitting cases to pass fresh orders, subject to depositing 10% of disputed tax within 30 days. Petition disposed by way of remand.
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