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 set aside the impugned order and remanded the matter to respondent No.5 for fresh reconsideration in accordance with law. This decision stemmed from the petitioner's intention to avail benefits under the Amnesty Scheme provided in Section 128(A) of the CGST Act, which offers waiver of interest and penalties for notices issued under Section 73. The Court deemed it just and appropriate to allow the petition through remand, issuing specific directions to guide the respondent's reconsideration of the matter in light of the petitioner's eligibility for amnesty benefits concerning interest and penalty waivers.
The HC set aside the impugned order and remanded the matter to respondent No.5 for fresh reconsideration in accordance with law. This decision stemmed from the petitioner's intention to avail benefits under the Amnesty Scheme provided in Section 128(A) of the CGST Act, which offers waiver of interest and penalties for notices issued under Section 73. The Court deemed it just and appropriate to allow the petition through remand, issuing specific directions to guide the respondent's reconsideration of the matter in light of the petitioner's eligibility for amnesty benefits concerning interest and penalty waivers.
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