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...
Respondent failed to reduce, re-fix and display MRPS commensurately after GST rate reduction on impacted SKUs w.e.f. 15.11.2017 and convey the same to dealers, thereby not passing on tax reduction benefit to consumers in violation of Section 171 of GST Act as per Delhi HC judgment [2024 (1) TMI 1248]. DGAP report stating no violation cannot be accepted. DGAP directed to reinvestigate case as per HC judgment and submit report u/r 133(4) of CGST Rules, 2017.
Respondent failed to reduce, re-fix and display MRPS commensurately after GST rate reduction on impacted SKUs w.e.f. 15.11.2017 and convey the same to dealers, thereby not passing on tax reduction benefit to consumers in violation of Section 171 of GST Act as per Delhi HC judgment [2024 (1) TMI 1248]. DGAP report stating no violation cannot be accepted. DGAP directed to reinvestigate case as per HC judgment and submit report u/r 133(4) of CGST Rules, 2017.
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