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 censured departmental actions in GST proceedings, emphasizing that the legislative intent behind the GST regime is not to disrupt businesses or compromise livelihoods. The court critically evaluated the punitive approach, highlighting that tax compliance should foster business growth and national economic development. The interim order mandates that all departmental actions must strictly adhere to GST Act provisions, with a focus on constructive engagement rather than punitive measures. The court's ruling underscores the need for a balanced regulatory approach that supports entrepreneurial sustainability and economic progress.
HC censured departmental actions in GST proceedings, emphasizing that the legislative intent behind the GST regime is not to disrupt businesses or compromise livelihoods. The court critically evaluated the punitive approach, highlighting that tax compliance should foster business growth and national economic development. The interim order mandates that all departmental actions must strictly adhere to GST Act provisions, with a focus on constructive engagement rather than punitive measures. The court's ruling underscores the need for a balanced regulatory approach that supports entrepreneurial sustainability and economic progress.
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