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 held that the respondent-authority had jurisdiction u/s 61 of the Jharkhand Goods and Services Tax Act, 2017 to issue a second show-cause notice seeking further explanation regarding discrepancies pointed out after the petitioner's response to the first show-cause notice. The Court opined that since the petitioner had furnished an explanation to the first notice, no prejudice would be caused by responding to the second notice highlighting additional discrepancies. The petitioner was directed to explain the alleged discrepancies mentioned in the second show-cause notice dated 05.07.2024 for the authority to proceed in accordance with law u/s 61 of the JGST Act. Consequently, the writ petition was disposed of.
The High Court held that the respondent-authority had jurisdiction u/s 61 of the Jharkhand Goods and Services Tax Act, 2017 to issue a second show-cause notice seeking further explanation regarding discrepancies pointed out after the petitioner's response to the first show-cause notice. The Court opined that since the petitioner had furnished an explanation to the first notice, no prejudice would be caused by responding to the second notice highlighting additional discrepancies. The petitioner was directed to explain the alleged discrepancies mentioned in the second show-cause notice dated 05.07.2024 for the authority to proceed in accordance with law u/s 61 of the JGST Act. Consequently, the writ petition was disposed of.
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