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...
Sections 16(2)(c) and 16(2)(d) of the Assam and Central Goods and Services Tax Acts, 2017, were challenged regarding the validity of punishing a purchasing dealer for the selling dealer's failure to deposit collected tax. The High Court held that the controversy is covered by the Delhi High Court's decision in On Quest Merchandising India Pvt. Ltd. case, where it was ruled that default assessment orders against purchasing dealers invoking Section 9(2)(g) of the DVAT Act for the selling dealer's default were set aside. Consequently, the impugned show cause notices and consequential orders were set aside in the present case. However, the Department can act against non-bona fide purchase transactions in accordance with the law. The writ petition was disposed of.
Sections 16(2)(c) and 16(2)(d) of the Assam and Central Goods and Services Tax Acts, 2017, were challenged regarding the validity of punishing a purchasing dealer for the selling dealer's failure to deposit collected tax. The High Court held that the controversy is covered by the Delhi High Court's decision in On Quest Merchandising India Pvt. Ltd. case, where it was ruled that default assessment orders against purchasing dealers invoking Section 9(2)(g) of the DVAT Act for the selling dealer's default were set aside. Consequently, the impugned show cause notices and consequential orders were set aside in the present case. However, the Department can act against non-bona fide purchase transactions in accordance with the law. The writ petition was disposed of.
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