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 dismissed petition of charitable trust operating marriage hall challenging GST liability. Trust failed to register under GST Act from July 2017 to January 2020, attempting to evade tax by issuing receipts as donations. Post-inspection registration and tax payment were not voluntary but to avoid penalties. Court upheld that trust's conduct constituted suppression and fraud under Section 74 of GST Act. Both Original Authority and Appellate Authority correctly applied law, finding deliberate tax evasion through non-registration and mischaracterization of payments. Trust liable for unpaid taxes and penalties, with no grounds for judicial interference.
HC dismissed petition of charitable trust operating marriage hall challenging GST liability. Trust failed to register under GST Act from July 2017 to January 2020, attempting to evade tax by issuing receipts as donations. Post-inspection registration and tax payment were not voluntary but to avoid penalties. Court upheld that trust's conduct constituted suppression and fraud under Section 74 of GST Act. Both Original Authority and Appellate Authority correctly applied law, finding deliberate tax evasion through non-registration and mischaracterization of payments. Trust liable for unpaid taxes and penalties, with no grounds for judicial interference.
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