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 upheld the constitutional validity of GST Circulars No. 3/3/2017 and 31/05/2018, dismissing challenges to their procedural legitimacy. The petitioner, lacking direct connection to the investigated firms, failed to establish standing. The court emphasized that challenges to administrative actions, particularly Show Cause Notices (SCNs), require concrete evidence of legal violations. Given the gravity of allegations involved, the court found no justifiable grounds to interfere with ongoing SCN proceedings under CGST Act, 2017. The determination of proper officers for GST functions was deemed valid within statutory framework. Petition dismissed, affirming administrative authority's procedural compliance.
HC upheld the constitutional validity of GST Circulars No. 3/3/2017 and 31/05/2018, dismissing challenges to their procedural legitimacy. The petitioner, lacking direct connection to the investigated firms, failed to establish standing. The court emphasized that challenges to administrative actions, particularly Show Cause Notices (SCNs), require concrete evidence of legal violations. Given the gravity of allegations involved, the court found no justifiable grounds to interfere with ongoing SCN proceedings under CGST Act, 2017. The determination of proper officers for GST functions was deemed valid within statutory framework. Petition dismissed, affirming administrative authority's procedural compliance.
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