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...
Maintainability of appeal against order under CGST/SGST Act adjudication on refund application dismissed. Appellant had option to pay amounts demanded or contest seizure and insist on adjudication order. Appellant chose payment, leading to release order without tax/penalty determination. If payment was mistake, appellant should have sought refund and adjudication on refund application. Appellant solely to blame for delay of over 7 years after release of goods. Writ Appeal dismissed, upholding Single Judge's dismissal of Writ Petition.
Maintainability of appeal against order under CGST/SGST Act adjudication on refund application dismissed. Appellant had option to pay amounts demanded or contest seizure and insist on adjudication order. Appellant chose payment, leading to release order without tax/penalty determination. If payment was mistake, appellant should have sought refund and adjudication on refund application. Appellant solely to blame for delay of over 7 years after release of goods. Writ Appeal dismissed, upholding Single Judge's dismissal of Writ Petition.
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