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 provisional attachment order under Section 83 of CGST Act, finding it legally deficient on multiple grounds. The order lacked tangible material justifying attachment necessity, failed to disclose substantive reasons beyond mere statutory reproduction, and showed no application of mind regarding jurisdictional elements. While Section 83 permits immediate action without pre-decisional hearing to protect revenue interests, it does not dispense with the requirement to provide reasoning. The Court rejected respondent's technical arguments about form limitations, emphasizing that fundamental principles of reasoned decision-making cannot be sacrificed for expediency. The attachment was invalidated for failing to demonstrate necessity through proper reasoning and for not considering less restrictive alternatives.
HC quashed provisional attachment order under Section 83 of CGST Act, finding it legally deficient on multiple grounds. The order lacked tangible material justifying attachment necessity, failed to disclose substantive reasons beyond mere statutory reproduction, and showed no application of mind regarding jurisdictional elements. While Section 83 permits immediate action without pre-decisional hearing to protect revenue interests, it does not dispense with the requirement to provide reasoning. The Court rejected respondent's technical arguments about form limitations, emphasizing that fundamental principles of reasoned decision-making cannot be sacrificed for expediency. The attachment was invalidated for failing to demonstrate necessity through proper reasoning and for not considering less restrictive alternatives.
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