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 quashed the order invoking Rule 86A for blocking the Electronic Credit Ledger (ECL) of the petitioner under the CGST/SGST Rules, 2017. The impugned order lacked independent or cogent reasons and relied on reports of enforcement authorities, which is impermissible. Crucially, no pre-decisional hearing was granted, violating principles of natural justice. The order erroneously described the supplier as non-existent or not conducting business, despite the supplier obtaining registration and the transaction occurring before cancellation of registration. The court held that the order failed to provide valid reasons for blocking the ECL, thereby warranting its quashing.
The High Court quashed the order invoking Rule 86A for blocking the Electronic Credit Ledger (ECL) of the petitioner under the CGST/SGST Rules, 2017. The impugned order lacked independent or cogent reasons and relied on reports of enforcement authorities, which is impermissible. Crucially, no pre-decisional hearing was granted, violating principles of natural justice. The order erroneously described the supplier as non-existent or not conducting business, despite the supplier obtaining registration and the transaction occurring before cancellation of registration. The court held that the order failed to provide valid reasons for blocking the ECL, thereby warranting its quashing.
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