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...
HC set aside the impugned order dated 26.06.2024 concerning GST tax discrepancies. Despite petitioner having already remitted approximately 90% of disputed taxes, court granted one final opportunity to present objections, adhering to principles of natural justice. Petitioner directed to deposit 25% of disputed tax amount within four weeks from order receipt. Decision balanced statutory compliance under GST Act, 2017 with procedural fairness, ensuring adequate notice and response opportunity. Respondent's counsel raised no objection to this arrangement. Matter concluded with petition disposal, emphasizing administrative law principles of fair hearing and reasonable opportunity.
HC set aside the impugned order dated 26.06.2024 concerning GST tax discrepancies. Despite petitioner having already remitted approximately 90% of disputed taxes, court granted one final opportunity to present objections, adhering to principles of natural justice. Petitioner directed to deposit 25% of disputed tax amount within four weeks from order receipt. Decision balanced statutory compliance under GST Act, 2017 with procedural fairness, ensuring adequate notice and response opportunity. Respondent's counsel raised no objection to this arrangement. Matter concluded with petition disposal, emphasizing administrative law principles of fair hearing and reasonable opportunity.
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