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 set aside the show cause notice and summary issued by the respondent u/s 74 of the Central Goods and Services Tax Act, 2017 for multiple financial years spanning January 2018 to August 2022. Relying on the coordinate bench judgment in M/S. VEREMAX TECHNOLOGIE SERVICES LIMITED, the Court held that the respondent erred in issuing a consolidated show cause notice for multiple assessment years from 2017-18 to 2020-21. Though the summary segregated liabilities for each financial year, the Court found it inappropriate. The respondent was granted liberty to issue separate show cause notices for each financial year and proceed against the petitioner accordingly.
The High Court set aside the show cause notice and summary issued by the respondent u/s 74 of the Central Goods and Services Tax Act, 2017 for multiple financial years spanning January 2018 to August 2022. Relying on the coordinate bench judgment in M/S. VEREMAX TECHNOLOGIE SERVICES LIMITED, the Court held that the respondent erred in issuing a consolidated show cause notice for multiple assessment years from 2017-18 to 2020-21. Though the summary segregated liabilities for each financial year, the Court found it inappropriate. The respondent was granted liberty to issue separate show cause notices for each financial year and proceed against the petitioner accordingly.
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