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...
Challenge to summons jurisdiction - parallel proceedings - Central Authorities' jurisdiction u/s 6(2) Central Goods and Service Tax Act, 2017. Petitioner has no objection to investigation regarding M/s IESA Sales Pvt. Ltd. Held: Respondent No.3 can investigate pursuant to summons dated 21.06.2024 and 05.07.2024 regarding M/s IESA Sales Pvt. Ltd. However, based on communication dated 09.08.2024, Respondent No.3 cannot further investigate Petitioner's transactions with M/s Ridhi Industries and M/s Amazonite Steels Private Ltd. for the relevant period. Petition disposed.
Challenge to summons jurisdiction - parallel proceedings - Central Authorities' jurisdiction u/s 6(2) Central Goods and Service Tax Act, 2017. Petitioner has no objection to investigation regarding M/s IESA Sales Pvt. Ltd. Held: Respondent No.3 can investigate pursuant to summons dated 21.06.2024 and 05.07.2024 regarding M/s IESA Sales Pvt. Ltd. However, based on communication dated 09.08.2024, Respondent No.3 cannot further investigate Petitioner's transactions with M/s Ridhi Industries and M/s Amazonite Steels Private Ltd. for the relevant period. Petition disposed.
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