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 challenging the demand raised by the respondent Greater NOIDA Industrial Development Authority from the petitioner towards GST and premium. The demand was set aside as it was a non-speaking order, violating the principles of natural justice and being contrary to notifications, advance ruling, and the Court's judgment. The respondent was permitted to raise a fresh demand by passing a detailed speaking order considering relevant notifications, advance ruling, the Court's judgment, and subsequent notifications before 05.12.2023, indicating the petitioner's liability to pay the GST amount.
The High Court allowed the petition challenging the demand raised by the respondent Greater NOIDA Industrial Development Authority from the petitioner towards GST and premium. The demand was set aside as it was a non-speaking order, violating the principles of natural justice and being contrary to notifications, advance ruling, and the Court's judgment. The respondent was permitted to raise a fresh demand by passing a detailed speaking order considering relevant notifications, advance ruling, the Court's judgment, and subsequent notifications before 05.12.2023, indicating the petitioner's liability to pay the GST amount.
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