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...
Unreasoned orders passed u/s 73 of the Central/Delhi Goods & Services Tax Act, 2017 violated principles of natural justice. The impugned orders were set aside, and matters remanded for fresh consideration by the adjudicating authority. The authority was directed not to pass adverse orders without affording reasonable opportunity of hearing to petitioners. All rights and contentions of petitioners were reserved, allowing them to raise issues including those raised in the present petitions. The High Court disposed of the petitions.
Unreasoned orders passed u/s 73 of the Central/Delhi Goods & Services Tax Act, 2017 violated principles of natural justice. The impugned orders were set aside, and matters remanded for fresh consideration by the adjudicating authority. The authority was directed not to pass adverse orders without affording reasonable opportunity of hearing to petitioners. All rights and contentions of petitioners were reserved, allowing them to raise issues including those raised in the present petitions. The High Court disposed of the petitions.
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