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...
Doctrine of mutuality - Levy of GST on services provided by association to members - Constitutional validity of relevant provisions of Central and State GST Acts questioned - Held, provisions are within legislative competence and do not violate fundamental rights or principles of taxation - However, retrospective operation from 01.07.2017 not permissible, provisions to have prospective effect from 01.01.2022 - Each activity of association to be examined independently to determine if it involves supply of goods/services for GST levy - Writ petitions dismissed with above observations.
Doctrine of mutuality - Levy of GST on services provided by association to members - Constitutional validity of relevant provisions of Central and State GST Acts questioned - Held, provisions are within legislative competence and do not violate fundamental rights or principles of taxation - However, retrospective operation from 01.07.2017 not permissible, provisions to have prospective effect from 01.01.2022 - Each activity of association to be examined independently to determine if it involves supply of goods/services for GST levy - Writ petitions dismissed with above observations.
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