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...
Writ petition challenging notice for failure to file GST returns on time and consequential recovery notice. Court held petitioner should have sought mandamus for adjudication on liability for interest u/s 50 of CGST/TNGST Act. Petition disposed directing respondents to pass fresh order on merits within three months, justifying interest payable when amounts credited to government's electronic ledger/register.
Writ petition challenging notice for failure to file GST returns on time and consequential recovery notice. Court held petitioner should have sought mandamus for adjudication on liability for interest u/s 50 of CGST/TNGST Act. Petition disposed directing respondents to pass fresh order on merits within three months, justifying interest payable when amounts credited to government's electronic ledger/register.
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