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 show-cause notice (SCN) in Form GST DRC-01, alleging that respondents sought to levy GST at 28% instead of the prevalent 18% rate paid since 2017. The court held that mere issuance of the SCN to the petitioner and not to counterparts cannot be deemed unlawful. Writ jurisdiction cannot be invoked solely based on the SCN issuance, as the petitioner has the right to file a reply and be heard before any order is passed. Furthermore, any order passed by the authorities is appealable under the CGST Act. Consequently, the writ petition lacked merit and was dismissed.
Petitioner challenged the show-cause notice (SCN) in Form GST DRC-01, alleging that respondents sought to levy GST at 28% instead of the prevalent 18% rate paid since 2017. The court held that mere issuance of the SCN to the petitioner and not to counterparts cannot be deemed unlawful. Writ jurisdiction cannot be invoked solely based on the SCN issuance, as the petitioner has the right to file a reply and be heard before any order is passed. Furthermore, any order passed by the authorities is appealable under the CGST Act. Consequently, the writ petition lacked merit and was dismissed.
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