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 provisional attachment orders under Section 83 of Gujarat GST Act 2017 against petitioner's bank accounts. Evidence revealed petitioner's involvement in issuing fraudulent bills and wrongful input tax credit claims, with estimated liability of Rs.12.33 crores. Court found legitimate grounds for attachment renewal after initial one-year period, distinguishing from RHC Global Exports precedent. Petitioner's modus operandi involved selling high-value goods without invoices while claiming ITC on lower-value items. Court determined no breach of Section 83, as attachment served to protect revenue interests during ongoing investigation involving ITC fraud exceeding Rs.18.97 crores. Petition dismissed, allowing continued attachment of bank accounts.
HC upheld provisional attachment orders under Section 83 of Gujarat GST Act 2017 against petitioner's bank accounts. Evidence revealed petitioner's involvement in issuing fraudulent bills and wrongful input tax credit claims, with estimated liability of Rs.12.33 crores. Court found legitimate grounds for attachment renewal after initial one-year period, distinguishing from RHC Global Exports precedent. Petitioner's modus operandi involved selling high-value goods without invoices while claiming ITC on lower-value items. Court determined no breach of Section 83, as attachment served to protect revenue interests during ongoing investigation involving ITC fraud exceeding Rs.18.97 crores. Petition dismissed, allowing continued attachment of bank accounts.
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