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...
Order challenged u/s 74(9) of the Uttar Pradesh Goods and Services Tax Act, 2017 quashed due to denial of opportunity for personal hearing, violating principles of natural justice. Relying on coordinate Bench judgment in Mahaveer Trading Company case, where impugned order was held unsustainable for being passed in gross violation of fundamental principles of natural justice. Factual matrix similar, no reason to take a different stand. Impugned order dated June 8, 2023 quashed, direction given to officer concerned to grant petitioner another opportunity of filing fresh reply, thereafter fix a date of hearing and pass a reasoned order. Petition disposed of.
Order challenged u/s 74(9) of the Uttar Pradesh Goods and Services Tax Act, 2017 quashed due to denial of opportunity for personal hearing, violating principles of natural justice. Relying on coordinate Bench judgment in Mahaveer Trading Company case, where impugned order was held unsustainable for being passed in gross violation of fundamental principles of natural justice. Factual matrix similar, no reason to take a different stand. Impugned order dated June 8, 2023 quashed, direction given to officer concerned to grant petitioner another opportunity of filing fresh reply, thereafter fix a date of hearing and pass a reasoned order. Petition disposed of.
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