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...
Contradictory findings by Appellate Authority regarding classification of bio-fertilizers produced by petitioner and another manufacturer under different chapters leading to disparate GST rates of 12% and 5% respectively. Impugned order classifying petitioner's bio-fertilizers under Chapter 3002 quashed and matter remanded to Appellate Authority for fresh consideration after providing opportunity of hearing to petitioner due to anomaly in classification.
Contradictory findings by Appellate Authority regarding classification of bio-fertilizers produced by petitioner and another manufacturer under different chapters leading to disparate GST rates of 12% and 5% respectively. Impugned order classifying petitioner's bio-fertilizers under Chapter 3002 quashed and matter remanded to Appellate Authority for fresh consideration after providing opportunity of hearing to petitioner due to anomaly in classification.
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