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 determined GST audit completion timeframe was compliant with Section 65 of CGST Act. Petitioner challenged SCNs under Sections 73 and 74, claiming audit exceeded statutory timeline. Court found additional documents were submitted by petitioner on 09.04.2024, which marked commencement of audit per Section 65 Explanation. Three-month completion requirement ran from this date, not initial notice. Final audit report was filed within prescribed period. While question of whether timeline is mandatory or directory remained open, Court dismissed petition finding audit was timely completed based on actual document submission date. Writ petition dismissed with no merit.
HC determined GST audit completion timeframe was compliant with Section 65 of CGST Act. Petitioner challenged SCNs under Sections 73 and 74, claiming audit exceeded statutory timeline. Court found additional documents were submitted by petitioner on 09.04.2024, which marked commencement of audit per Section 65 Explanation. Three-month completion requirement ran from this date, not initial notice. Final audit report was filed within prescribed period. While question of whether timeline is mandatory or directory remained open, Court dismissed petition finding audit was timely completed based on actual document submission date. Writ petition dismissed with no merit.
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