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 payment procedures for GST demands under rule 142. Petitioner paid demand through Form GST DRC-03 instead of required electronic liability register Form GST PMT-01. Following recent amendment via notification 12/24 introducing rule 142(2B), petitioner permitted to file Form GST DRC-03A electronically to transfer payment credit to electronic liability register. Court directed that if petitioner files refund application under Section 54, authorities must process and refund amount to electronic cash/credit ledger within two weeks. Petition disposed with directive to follow amended procedure for payment adjustment through proper forms.
HC addressed payment procedures for GST demands under rule 142. Petitioner paid demand through Form GST DRC-03 instead of required electronic liability register Form GST PMT-01. Following recent amendment via notification 12/24 introducing rule 142(2B), petitioner permitted to file Form GST DRC-03A electronically to transfer payment credit to electronic liability register. Court directed that if petitioner files refund application under Section 54, authorities must process and refund amount to electronic cash/credit ledger within two weeks. Petition disposed with directive to follow amended procedure for payment adjustment through proper forms.
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