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...
Petitioner challenged SCN alleging conspiracy to issue fake invoices without actual supply using another entity's GST registration for tax evasion. HC held petitioner has remedy to file objection for adjudication on merits. Mere assertion of lack of jurisdiction or abuse of process insufficient for invoking Article 226. When factual adjudication required, Article 226 interference ruled out as held in UOI v. Vicco Labs. Petitioner's reasons agitable before adjudicating authority itself. No grounds to entertain petition under Article 226. Petitioner relegated to pursue statutory remedies. Petition dismissed.
Petitioner challenged SCN alleging conspiracy to issue fake invoices without actual supply using another entity's GST registration for tax evasion. HC held petitioner has remedy to file objection for adjudication on merits. Mere assertion of lack of jurisdiction or abuse of process insufficient for invoking Article 226. When factual adjudication required, Article 226 interference ruled out as held in UOI v. Vicco Labs. Petitioner's reasons agitable before adjudicating authority itself. No grounds to entertain petition under Article 226. Petitioner relegated to pursue statutory remedies. Petition dismissed.
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