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 held that the Show Cause Notice (SCN) demanding Integrated Goods and Services Tax (IGST) on the activity of holding equity capital by the Holding Companies in the Petitioner company and on the External Commercial Borrowing (ECB) received by the Petitioner from AOSH was not properly considered. The court quashed the SCN insofar as it relates to the proposal to levy/demand GST on 'Continuous Equity Share holding' and remitted the matter back to the respondent for reconsideration after providing an opportunity to the petitioner regarding the issue of 'Value of the Credit Grant in Service determined as a service fee @1%'. The petitioner was granted liberty to submit its response on this issue within four weeks.
The High Court held that the Show Cause Notice (SCN) demanding Integrated Goods and Services Tax (IGST) on the activity of holding equity capital by the Holding Companies in the Petitioner company and on the External Commercial Borrowing (ECB) received by the Petitioner from AOSH was not properly considered. The court quashed the SCN insofar as it relates to the proposal to levy/demand GST on 'Continuous Equity Share holding' and remitted the matter back to the respondent for reconsideration after providing an opportunity to the petitioner regarding the issue of 'Value of the Credit Grant in Service determined as a service fee @1%'. The petitioner was granted liberty to submit its response on this issue within four weeks.
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