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 order u/s 74(9) of the Central Goods and Services Tax Act, 2017 - petitioner denied access to relied upon documents despite requests - alleged violation of principles of natural justice. Held: Petitioner afforded ample opportunity for hearing by respondent authority as per impugned order. In view of Supreme Court decision in Assistant Commissioner of State Tax and Others v. M/s Commercial Steel Limited, petitioner relegated to avail alternative remedy u/s 107 of the Act. Petition disposed of with liberty to initiate appropriate proceedings before appropriate authority in accordance with law.
Challenge to order u/s 74(9) of the Central Goods and Services Tax Act, 2017 - petitioner denied access to relied upon documents despite requests - alleged violation of principles of natural justice. Held: Petitioner afforded ample opportunity for hearing by respondent authority as per impugned order. In view of Supreme Court decision in Assistant Commissioner of State Tax and Others v. M/s Commercial Steel Limited, petitioner relegated to avail alternative remedy u/s 107 of the Act. Petition disposed of with liberty to initiate appropriate proceedings before appropriate authority in accordance with law.
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