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...
Petitioner challenged the impugned order alleging violation of principles of natural justice, being unaware of the order and preceding notices, and discrepancy between GSTR 1 and GSTR 3B filings. The High Court found the petitioner may have a case on merits, set aside the impugned order, and remitted the case to the respondent for fresh orders on merits and in accordance with law, subject to the petitioner depositing 25% of disputed tax within 30 days. The quashed impugned order shall be treated as an addendum to the preceding show cause notice. The petition was disposed of.
Petitioner challenged the impugned order alleging violation of principles of natural justice, being unaware of the order and preceding notices, and discrepancy between GSTR 1 and GSTR 3B filings. The High Court found the petitioner may have a case on merits, set aside the impugned order, and remitted the case to the respondent for fresh orders on merits and in accordance with law, subject to the petitioner depositing 25% of disputed tax within 30 days. The quashed impugned order shall be treated as an addendum to the preceding show cause notice. The petition was disposed of.
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