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 allowed the petition and directed the respondent No. 2, a government entity, to pay the petitioner the difference in GST amount at the enhanced rate of 18% instead of 12% for the period from 01.01.2022 to 30.09.2022 within three months, failing which the petitioner shall be entitled to interest at 6% per annum from the date of entitlement. The Court rejected the objections raised by respondents No. 2 & 3 regarding the maintainability of the writ petition and availability of alternative remedy under the Arbitration Act, as no disputed questions of fact were involved in the case.
The High Court allowed the petition and directed the respondent No. 2, a government entity, to pay the petitioner the difference in GST amount at the enhanced rate of 18% instead of 12% for the period from 01.01.2022 to 30.09.2022 within three months, failing which the petitioner shall be entitled to interest at 6% per annum from the date of entitlement. The Court rejected the objections raised by respondents No. 2 & 3 regarding the maintainability of the writ petition and availability of alternative remedy under the Arbitration Act, as no disputed questions of fact were involved in the case.
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