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 petition challenging the provisional attachment of the petitioner's bank accounts u/s 83(1) of the CGST/DGST Act. The court held that the pre-condition of initiation of proceedings under Chapter XII, XIV or XV was satisfied as proceedings u/s 67 had commenced prior to the attachment order. The contention that the attachment order's validity was limited until the conclusion of Section 67 proceedings was rejected. The court clarified that the only requirement is the commencement of proceedings under the relevant chapters, which was fulfilled. The petitioner's argument that the order should be set aside due to the controversy involving a question of law was also dismissed, as the object of provisional attachment u/s 83(1) is to protect government revenue, irrespective of the nature of the controversy. The court found the attachment order justified to safeguard government revenue based on the estimated GST value allegedly unpaid by the petitioner.
The High Court dismissed the petition challenging the provisional attachment of the petitioner's bank accounts u/s 83(1) of the CGST/DGST Act. The court held that the pre-condition of initiation of proceedings under Chapter XII, XIV or XV was satisfied as proceedings u/s 67 had commenced prior to the attachment order. The contention that the attachment order's validity was limited until the conclusion of Section 67 proceedings was rejected. The court clarified that the only requirement is the commencement of proceedings under the relevant chapters, which was fulfilled. The petitioner's argument that the order should be set aside due to the controversy involving a question of law was also dismissed, as the object of provisional attachment u/s 83(1) is to protect government revenue, irrespective of the nature of the controversy. The court found the attachment order justified to safeguard government revenue based on the estimated GST value allegedly unpaid by the petitioner.
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