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...
Amnesty scheme - Failure to file annual returns from financial year 2018-2019 till 01.04.2023, but filed before 31.08.2023. Justification for continuing notices for non-payment of late fees for belated GSTR-9C filed before 01.04.2023. Court held, relying on Anishia Chandrakanth v. Superintendent judgment, no justification for continuing notices for non-payment of late fees for belated GSTR-9C filed before 01.04.2023, when one-time amnesty commences. Ext.P3 set aside to extent seeking late fees for delay in filing GSTR-9C. However, petitioner not entitled to refund of late fees already paid over Rs. 10,000/-. Writ petition disposed of.
Amnesty scheme - Failure to file annual returns from financial year 2018-2019 till 01.04.2023, but filed before 31.08.2023. Justification for continuing notices for non-payment of late fees for belated GSTR-9C filed before 01.04.2023. Court held, relying on Anishia Chandrakanth v. Superintendent judgment, no justification for continuing notices for non-payment of late fees for belated GSTR-9C filed before 01.04.2023, when one-time amnesty commences. Ext.P3 set aside to extent seeking late fees for delay in filing GSTR-9C. However, petitioner not entitled to refund of late fees already paid over Rs. 10,000/-. Writ petition disposed of.
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