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 granted relief to the petitioner by directing the release of attachment over immovable properties due to discrepancies between GSTR 3B returns and auto-populated GSTR 2A. Despite making the requisite 10% pre-deposit of the disputed tax demand, the attachment was effected contrary to statutory provisions. The court held that once the pre-deposit is made u/s 107(7), recovery proceedings for the balance amount shall be deemed stayed. Consequently, the attachment of the petitioner's immovable properties was found unsustainable and ordered to be released.
The High Court granted relief to the petitioner by directing the release of attachment over immovable properties due to discrepancies between GSTR 3B returns and auto-populated GSTR 2A. Despite making the requisite 10% pre-deposit of the disputed tax demand, the attachment was effected contrary to statutory provisions. The court held that once the pre-deposit is made u/s 107(7), recovery proceedings for the balance amount shall be deemed stayed. Consequently, the attachment of the petitioner's immovable properties was found unsustainable and ordered to be released.
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