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 impugned orders of tax assessments for the period 2017-18 to 2022-23 against the petitioner and directed the Assessing Authority to redo the assessments after examining the applicability of Notification No.9 of 2017 dated 28.06.2017. The Court found merit in the petitioner's contention that if the petitioner is a unit of the Nuclear Fuel Complex/Department of Atomic Energy under the Central Government, the services rendered would be covered under the said notification, exempting them from Goods and Services Tax under Article 265 of the Constitution.
The High Court set aside the impugned orders of tax assessments for the period 2017-18 to 2022-23 against the petitioner and directed the Assessing Authority to redo the assessments after examining the applicability of Notification No.9 of 2017 dated 28.06.2017. The Court found merit in the petitioner's contention that if the petitioner is a unit of the Nuclear Fuel Complex/Department of Atomic Energy under the Central Government, the services rendered would be covered under the said notification, exempting them from Goods and Services Tax under Article 265 of the Constitution.
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