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 dismissed the petition challenging the proceedings initiated by the respondents u/s 65 of the CGST Act, 2017 for conducting audit. The Court held that the Commissioner can conduct the audit at prescribed frequency and manner without any embargo or time period restriction. The audit is akin to a preliminary inquiry, and the Department should not be prevented from conducting such inquiry into the books of accounts of a registered person, causing no prejudice. Consequently, there were no reasons to interfere with the audit proceedings.
The High Court dismissed the petition challenging the proceedings initiated by the respondents u/s 65 of the CGST Act, 2017 for conducting audit. The Court held that the Commissioner can conduct the audit at prescribed frequency and manner without any embargo or time period restriction. The audit is akin to a preliminary inquiry, and the Department should not be prevented from conducting such inquiry into the books of accounts of a registered person, causing no prejudice. Consequently, there were no reasons to interfere with the audit proceedings.
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