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...
Challenge to adjudication order u/s 73(9) of CGST/WBGST Act, 2017 - petitioners claimed no opportunity of hearing, violating principles of natural justice and CBIC circular. Court held petitioners' response was considered by proper officer as noted in order. Sufficiency of response cannot be subject matter of writ petition under Article 226. Though petitioners claimed violation of statutory provisions by not affording hearing, it was an afterthought as they did not file appeal within limitation period or approach Court expeditiously. Court granted leave to prefer appeal on payment of costs, subject to filing within two weeks. Petition disposed of.
Challenge to adjudication order u/s 73(9) of CGST/WBGST Act, 2017 - petitioners claimed no opportunity of hearing, violating principles of natural justice and CBIC circular. Court held petitioners' response was considered by proper officer as noted in order. Sufficiency of response cannot be subject matter of writ petition under Article 226. Though petitioners claimed violation of statutory provisions by not affording hearing, it was an afterthought as they did not file appeal within limitation period or approach Court expeditiously. Court granted leave to prefer appeal on payment of costs, subject to filing within two weeks. Petition disposed of.
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