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 regarding time limitation and GSTR-3B/GSTR-2A mismatch dispute. The petitioner's willingness to deposit 25% of disputed tax amount was considered favorably. Court granted relief by directing petitioner to deposit the agreed percentage within four weeks from order receipt, allowing a final opportunity to present objections before the adjudicating authority. The decision balances tax compliance requirements with procedural fairness, enabling the petitioner to pursue substantive arguments while ensuring partial tax recovery. Matter remanded for fresh consideration upon compliance with deposit condition.
HC set aside the impugned order regarding time limitation and GSTR-3B/GSTR-2A mismatch dispute. The petitioner's willingness to deposit 25% of disputed tax amount was considered favorably. Court granted relief by directing petitioner to deposit the agreed percentage within four weeks from order receipt, allowing a final opportunity to present objections before the adjudicating authority. The decision balances tax compliance requirements with procedural fairness, enabling the petitioner to pursue substantive arguments while ensuring partial tax recovery. Matter remanded for fresh consideration upon compliance with deposit condition.
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