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 dismissed writ petition challenging GST reassessment order, holding that statutory appeal under Section 107A GST Act provides adequate remedy. Court emphasized established principle that writ jurisdiction cannot be invoked when statutory remedies exist, absent exceptional circumstances. Petitioner's claims of natural justice violations and denial of witness cross-examination were directed to appellate forum. Court granted petitioner 30 days from judgment date to file statutory appeal, ensuring preservation of appellate rights despite writ dismissal. Dismissal was without prejudice to merits, allowing full ventilation of grievances through prescribed appellate mechanism.
HC dismissed writ petition challenging GST reassessment order, holding that statutory appeal under Section 107A GST Act provides adequate remedy. Court emphasized established principle that writ jurisdiction cannot be invoked when statutory remedies exist, absent exceptional circumstances. Petitioner's claims of natural justice violations and denial of witness cross-examination were directed to appellate forum. Court granted petitioner 30 days from judgment date to file statutory appeal, ensuring preservation of appellate rights despite writ dismissal. Dismissal was without prejudice to merits, allowing full ventilation of grievances through prescribed appellate mechanism.
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