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...
Violation of principles of natural justice occurred as petitioner's contentions were not considered - mismatch between petitioner's GSTR 3B returns and auto-populated GSTR 2A - third respondent failed to discuss petitioner's explanation for classifying product as farm tractor or record reasons for rejecting such explanation - regarding ITC mismatch, petitioner referred to issuance of invoices after financial year-end, but third respondent erroneously recorded petitioner's contention as ITC matching not being mandatory requirement - impugned order partly set aside concerning ITC mismatch and rate of tax difference/classification issues - third respondent directed to provide reasonable opportunity, including personal hearing, and issue fresh order within three months - petition disposed of.
Violation of principles of natural justice occurred as petitioner's contentions were not considered - mismatch between petitioner's GSTR 3B returns and auto-populated GSTR 2A - third respondent failed to discuss petitioner's explanation for classifying product as farm tractor or record reasons for rejecting such explanation - regarding ITC mismatch, petitioner referred to issuance of invoices after financial year-end, but third respondent erroneously recorded petitioner's contention as ITC matching not being mandatory requirement - impugned order partly set aside concerning ITC mismatch and rate of tax difference/classification issues - third respondent directed to provide reasonable opportunity, including personal hearing, and issue fresh order within three months - petition disposed of.
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