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 addressed procedural challenge regarding timing of notice issued before expiry of response period to Form GSTR DRC-01A. While petitioner initially contested DRC-01A validity, scope narrowed to requesting underlying materials from authorities. Court affirmed petitioner's right to request documentation and raise jurisdictional objections in response to DRC-01A. Authorities directed to consider such requests per law, ensuring reasonable hearing opportunity. Notably, court preserved petitioner's right to raise all available defenses while maintaining procedural safeguards. Matter disposed with directive to authorities to process any subsequent requests in accordance with statutory provisions.
HC addressed procedural challenge regarding timing of notice issued before expiry of response period to Form GSTR DRC-01A. While petitioner initially contested DRC-01A validity, scope narrowed to requesting underlying materials from authorities. Court affirmed petitioner's right to request documentation and raise jurisdictional objections in response to DRC-01A. Authorities directed to consider such requests per law, ensuring reasonable hearing opportunity. Notably, court preserved petitioner's right to raise all available defenses while maintaining procedural safeguards. Matter disposed with directive to authorities to process any subsequent requests in accordance with statutory provisions.
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