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...
High Court rejected petitioner's writ petition challenging refund rejection order, observing that respondent authority had passed reasoned order after considering petitioner's reply and deficiencies in refund application. Court held that petitioner ought to have availed statutory appeal remedy instead of directly approaching Court. Under Article 226, High Court's jurisdiction in certiorari is supervisory, limited to correcting errors of jurisdiction or natural justice violations, not re-appreciating evidence. Appellate forum offers wider canvas than writ jurisdiction. Petition dismissed, with liberty to pursue statutory appeal.
High Court rejected petitioner's writ petition challenging refund rejection order, observing that respondent authority had passed reasoned order after considering petitioner's reply and deficiencies in refund application. Court held that petitioner ought to have availed statutory appeal remedy instead of directly approaching Court. Under Article 226, High Court's jurisdiction in certiorari is supervisory, limited to correcting errors of jurisdiction or natural justice violations, not re-appreciating evidence. Appellate forum offers wider canvas than writ jurisdiction. Petition dismissed, with liberty to pursue statutory appeal.
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