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...
The HC disposed of the petition challenging a GST assessment order characterized as non-speaking and violative of Section 75(6) of the GST Act. Rather than adjudicating on merits, the Court granted the petitioner liberty to approach the appellate Deputy Commissioner (State Tax) within two weeks, directing the appellate authority to entertain the appeal without reference to limitation periods and dispose of it within three months. The Court ordered status quo to be maintained in the interim. The petitioner was permitted to raise all grounds from the writ petition in the appeal, including violations of natural justice principles and the non-speaking nature of the impugned order.
The HC disposed of the petition challenging a GST assessment order characterized as non-speaking and violative of Section 75(6) of the GST Act. Rather than adjudicating on merits, the Court granted the petitioner liberty to approach the appellate Deputy Commissioner (State Tax) within two weeks, directing the appellate authority to entertain the appeal without reference to limitation periods and dispose of it within three months. The Court ordered status quo to be maintained in the interim. The petitioner was permitted to raise all grounds from the writ petition in the appeal, including violations of natural justice principles and the non-speaking nature of the impugned order.
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