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 addressed maintainability of GST petition where appellant sought stay on tax recovery due to non-constitution of GST Tribunal. Following legislative amendment to Section 112 of CGST Act 2017, pre-deposit requirement was reduced from 20% to 10% for appeals. Despite Tribunal's non-existence, court granted interim relief based on precedent, allowing assessee to deposit 10% of disputed tax amount in addition to amount already deposited under Section 107(6). Court held that petitioner cannot be denied statutory benefit under Section 112(9) due to administrative delay in Tribunal formation. Recovery proceedings for balance amount stayed until Tribunal constitution and appeal filing. Petition disposed with direction to comply with modified deposit requirement.
HC addressed maintainability of GST petition where appellant sought stay on tax recovery due to non-constitution of GST Tribunal. Following legislative amendment to Section 112 of CGST Act 2017, pre-deposit requirement was reduced from 20% to 10% for appeals. Despite Tribunal's non-existence, court granted interim relief based on precedent, allowing assessee to deposit 10% of disputed tax amount in addition to amount already deposited under Section 107(6). Court held that petitioner cannot be denied statutory benefit under Section 112(9) due to administrative delay in Tribunal formation. Recovery proceedings for balance amount stayed until Tribunal constitution and appeal filing. Petition disposed with direction to comply with modified deposit requirement.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4798
Join Channel
TaxTMI 
