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 petitioner challenged the issuance of multiple audit memos determining tax liability beyond the stipulated period u/s 65(4) of the CGST/DGST Act. While the multiple audit memos indicating findings and demanding tax payment were irregular u/s 65(6), the impugned show cause notice (SCN) premised on the audit report findings is within the statutory framework. Any irregularities in issuing audit memos do not impinge the validity of the SCN. Therefore, the petition to quash the SCN at the threshold stage cannot be accepted, and the petition is disposed of.
The petitioner challenged the issuance of multiple audit memos determining tax liability beyond the stipulated period u/s 65(4) of the CGST/DGST Act. While the multiple audit memos indicating findings and demanding tax payment were irregular u/s 65(6), the impugned show cause notice (SCN) premised on the audit report findings is within the statutory framework. Any irregularities in issuing audit memos do not impinge the validity of the SCN. Therefore, the petition to quash the SCN at the threshold stage cannot be accepted, and the petition is disposed of.
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