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...
Impugned order and show cause notice quashed due to lack of digital or physical signature by issuing authority as mandated by Rule 26 of CGST Rules and TGST Act and Rules. Unsigned documents rendered ineffective. However, respondents' right reserved to initiate appropriate proceedings in accordance with applicable laws.
Impugned order and show cause notice quashed due to lack of digital or physical signature by issuing authority as mandated by Rule 26 of CGST Rules and TGST Act and Rules. Unsigned documents rendered ineffective. However, respondents' right reserved to initiate appropriate proceedings in accordance with applicable laws.
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