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...
Validity of notice issued u/s 73 of the U.P. Goods and Services Tax Act, 2017 challenged due to non-consideration of petitioner's reply, violating principles of natural justice. Court held petitioner's grievance valid as notice contained facts and figures relating to unrelated entity. Directed respondent to consider petitioner's reply regarding its own company and mismatch/deficiencies, if any. Petitioner granted one week to submit detailed reply to Section 73 notice referring only to its own returns, not unrelated entity's case. Petitioner allowed to deny liability regarding notice addressed to unrelated entity. Writ petition disposed of.
Validity of notice issued u/s 73 of the U.P. Goods and Services Tax Act, 2017 challenged due to non-consideration of petitioner's reply, violating principles of natural justice. Court held petitioner's grievance valid as notice contained facts and figures relating to unrelated entity. Directed respondent to consider petitioner's reply regarding its own company and mismatch/deficiencies, if any. Petitioner granted one week to submit detailed reply to Section 73 notice referring only to its own returns, not unrelated entity's case. Petitioner allowed to deny liability regarding notice addressed to unrelated entity. Writ petition disposed of.
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