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 court quashed orders related to audit and intimation liability issued against the petitioner company u/s 65 of the CGST Act for financial years 2018-19 and 2019-20. The orders were found to be without jurisdiction or legal authority, as a resolution plan for the company had already been approved by the NCLT, rendering such proceedings impermissible under applicable legal precedents. Consequently, the petition challenging the impugned orders and proceedings was allowed by the High Court.
The court quashed orders related to audit and intimation liability issued against the petitioner company u/s 65 of the CGST Act for financial years 2018-19 and 2019-20. The orders were found to be without jurisdiction or legal authority, as a resolution plan for the company had already been approved by the NCLT, rendering such proceedings impermissible under applicable legal precedents. Consequently, the petition challenging the impugned orders and proceedings was allowed by the High Court.
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