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...
Petition challenged impugned order passed by respondent for assessment year 2018-19, contending violation of principles of natural justice due to non-issuance of notices. Court held petitioner may have merits as dispute pertained to difference in turnover reported in GSTR-7 and GSTR-3B. Partial relief granted by setting aside impugned order and remitting case to respondent for fresh order on merits. Impugned order quashed, treated as addendum to show cause notices. Petitioner directed to file consolidated reply within 30 days and deposit 20% of disputed tax from electronic cash register. Petition disposed off by way of remand.
Petition challenged impugned order passed by respondent for assessment year 2018-19, contending violation of principles of natural justice due to non-issuance of notices. Court held petitioner may have merits as dispute pertained to difference in turnover reported in GSTR-7 and GSTR-3B. Partial relief granted by setting aside impugned order and remitting case to respondent for fresh order on merits. Impugned order quashed, treated as addendum to show cause notices. Petitioner directed to file consolidated reply within 30 days and deposit 20% of disputed tax from electronic cash register. Petition disposed off by way of remand.
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