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 granted time to the respondents to file a reply challenging the circular dated 27.10.2023 and the petitioner's contention that providing a corporate guarantee by a holding company to its subsidiary does not constitute a "supply" or "supply of service" taxable u/s 9 of the CGST Act, 2017. The HC stayed the operation of the impugned circular dated 27.10.2023 regarding Item No. 2 until further orders.
The HC granted time to the respondents to file a reply challenging the circular dated 27.10.2023 and the petitioner's contention that providing a corporate guarantee by a holding company to its subsidiary does not constitute a "supply" or "supply of service" taxable u/s 9 of the CGST Act, 2017. The HC stayed the operation of the impugned circular dated 27.10.2023 regarding Item No. 2 until further orders.
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