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...
Excess stock found during survey triggers proceedings u/ss 73/74 of the GST Act, not Section 130. The authority noted excess stock by eye estimation without physical verification or video recording. The High Court held that if excess stock is found, proceedings u/ss 73/74 should be initiated, not Section 130 read with Rule 120. The impugned orders initiating proceedings u/s 130 were quashed as legally unsustainable when excess stock was found during the survey.
Excess stock found during survey triggers proceedings u/ss 73/74 of the GST Act, not Section 130. The authority noted excess stock by eye estimation without physical verification or video recording. The High Court held that if excess stock is found, proceedings u/ss 73/74 should be initiated, not Section 130 read with Rule 120. The impugned orders initiating proceedings u/s 130 were quashed as legally unsustainable when excess stock was found during the survey.
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