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 declined to entertain writ petition challenging Principal Commissioner's ex parte Service Tax liability order, directing petitioner to pursue statutory appeal remedy. Court noted petitioner had previously withdrawn similar petition (CWJC 9292/2010) and already deposited 7.5% pre-deposit for appeal. While HC retained discretionary power to hear writs despite alternative remedies, circumstances warranted relegation to appellate process. Petitioner granted 8 weeks to file appeal, with Appellate Authority directed to consider limitation period excluding time spent in current proceedings since 19.08.2024. Previous liberty to file fresh writ petition held immaterial given available statutory remedy. Matter disposed with appellate pathway preserved.
HC declined to entertain writ petition challenging Principal Commissioner's ex parte Service Tax liability order, directing petitioner to pursue statutory appeal remedy. Court noted petitioner had previously withdrawn similar petition (CWJC 9292/2010) and already deposited 7.5% pre-deposit for appeal. While HC retained discretionary power to hear writs despite alternative remedies, circumstances warranted relegation to appellate process. Petitioner granted 8 weeks to file appeal, with Appellate Authority directed to consider limitation period excluding time spent in current proceedings since 19.08.2024. Previous liberty to file fresh writ petition held immaterial given available statutory remedy. Matter disposed with appellate pathway preserved.
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