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 set aside the impugned orders and consequential GST DRC-13 notice for attachment of Bank Account issued by the tax authority for the assessment year 2017-2018. The issue pertained to a mismatch of tax liability between GSTR-3B and GSTR-2A filed by the petitioner. The Court held that the principles of natural justice were violated as the show cause notice was uploaded on the GST Portal, and the petitioner was unaware of its issuance. The impugned order was passed without affording an opportunity of personal hearing to the petitioner to establish its case. Consequently, the Court provided an opportunity to the petitioner to establish their case on merits and in accordance with law, subject to conditions imposed.
The High Court set aside the impugned orders and consequential GST DRC-13 notice for attachment of Bank Account issued by the tax authority for the assessment year 2017-2018. The issue pertained to a mismatch of tax liability between GSTR-3B and GSTR-2A filed by the petitioner. The Court held that the principles of natural justice were violated as the show cause notice was uploaded on the GST Portal, and the petitioner was unaware of its issuance. The impugned order was passed without affording an opportunity of personal hearing to the petitioner to establish its case. Consequently, the Court provided an opportunity to the petitioner to establish their case on merits and in accordance with law, subject to conditions imposed.
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