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 quashed demand order and show cause notice issued under Section 73 of UP GST Act 2017. For FY 2017-18, annual return filing deadline was extended to 05.02.2020. Per Section 73(10), three-year limitation period for passing assessment order would expire on 05.02.2023. Assessment order dated 02.12.2023 was time-barred as it exceeded statutory limitation period. Court held orders dated 02.12.2023 and 29.09.2023 passed by Asst. Commissioner were void being beyond limitation period prescribed under Section 73. Petition allowed with orders quashed for being time-barred.
HC quashed demand order and show cause notice issued under Section 73 of UP GST Act 2017. For FY 2017-18, annual return filing deadline was extended to 05.02.2020. Per Section 73(10), three-year limitation period for passing assessment order would expire on 05.02.2023. Assessment order dated 02.12.2023 was time-barred as it exceeded statutory limitation period. Court held orders dated 02.12.2023 and 29.09.2023 passed by Asst. Commissioner were void being beyond limitation period prescribed under Section 73. Petition allowed with orders quashed for being time-barred.
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