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 that the petitioner failed to demonstrate procedural irregularities in tax credit proceedings. Despite claims of inadequate document disclosure, the court found all Relied Upon Documents were properly supplied and adequate hearing opportunities provided. The court rejected allegations of natural justice violations, noting the petitioner's deliberate non-participation in adjudication proceedings. The ruling directed the petitioner to pursue remedies under Section 107 of CGST Act, affirming the original order's validity. Cash seizure was not upheld as the CGST Act does not categorize cash as "goods". Petition was ultimately disposed of, maintaining the original administrative order's substantive findings.
HC determined that the petitioner failed to demonstrate procedural irregularities in tax credit proceedings. Despite claims of inadequate document disclosure, the court found all Relied Upon Documents were properly supplied and adequate hearing opportunities provided. The court rejected allegations of natural justice violations, noting the petitioner's deliberate non-participation in adjudication proceedings. The ruling directed the petitioner to pursue remedies under Section 107 of CGST Act, affirming the original order's validity. Cash seizure was not upheld as the CGST Act does not categorize cash as "goods". Petition was ultimately disposed of, maintaining the original administrative order's substantive findings.
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