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 HC set aside the impugned order and remitted the matter back to the respondent to pass a fresh order considering the Supreme Court's judgment in Union of India & Anr. v. M/s Mohit Minerals Pvt. Ltd. on non-payment of IGST under reverse charge mechanism for import of services relating to transportation of goods by vessel. The writ petition was allowed by way of remand.
The HC set aside the impugned order and remitted the matter back to the respondent to pass a fresh order considering the Supreme Court's judgment in Union of India & Anr. v. M/s Mohit Minerals Pvt. Ltd. on non-payment of IGST under reverse charge mechanism for import of services relating to transportation of goods by vessel. The writ petition was allowed by way of remand.
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