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...
Petitioner contested order regarding deficient monthly returns and lack of supporting documentation. Following precedent in K. Balakrishnan case, HC set aside the impugned order. Petitioner demonstrated willingness to pay 25% of disputed tax amount and requested final opportunity for presenting objections before adjudicating authority. Government Pleader raised no substantial opposition. HC disposed of writ petition by setting aside original order, allowing petitioner to present case before adjudicating authority with commitment to partial tax payment, aligning with established GST procedural jurisprudence on opportunities for taxpayer representation.
Petitioner contested order regarding deficient monthly returns and lack of supporting documentation. Following precedent in K. Balakrishnan case, HC set aside the impugned order. Petitioner demonstrated willingness to pay 25% of disputed tax amount and requested final opportunity for presenting objections before adjudicating authority. Government Pleader raised no substantial opposition. HC disposed of writ petition by setting aside original order, allowing petitioner to present case before adjudicating authority with commitment to partial tax payment, aligning with established GST procedural jurisprudence on opportunities for taxpayer representation.
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