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...
Petitioner paid IGST but respondent did not take benefit of ITC. Dispute not settled. Appellate authority to consider grievance regarding payment of penalty and interest if petitioner made bona fide mistake in paying IGST instead of CGST and SGST. Petitioner directed to approach appellate authority u/s 107 within two weeks along with application for interim relief. If such application filed, appellate authority to consider it within two weeks and pass reasoned order.
Petitioner paid IGST but respondent did not take benefit of ITC. Dispute not settled. Appellate authority to consider grievance regarding payment of penalty and interest if petitioner made bona fide mistake in paying IGST instead of CGST and SGST. Petitioner directed to approach appellate authority u/s 107 within two weeks along with application for interim relief. If such application filed, appellate authority to consider it within two weeks and pass reasoned order.
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