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...
The High Court dismissed the writ petition challenging the jurisdiction of carrying out show cause notice proceedings and the scope for seizure or confiscation of cash. The court held that the petitioner cannot scuttle the show cause proceedings initiated under the GST enactments, despite a favorable order from the Tribunal in another case. The impugned show cause notice sought to appropriate the amount seized from the petitioner's partner on a specific date towards the petitioner's tax liability under the GST laws. The petitioner was directed to participate in the show cause notice proceeding by filing a proper reply within 30 days from the receipt of the order.
The High Court dismissed the writ petition challenging the jurisdiction of carrying out show cause notice proceedings and the scope for seizure or confiscation of cash. The court held that the petitioner cannot scuttle the show cause proceedings initiated under the GST enactments, despite a favorable order from the Tribunal in another case. The impugned show cause notice sought to appropriate the amount seized from the petitioner's partner on a specific date towards the petitioner's tax liability under the GST laws. The petitioner was directed to participate in the show cause notice proceeding by filing a proper reply within 30 days from the receipt of the order.
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