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 ruled that blocking of Electronic Credit Ledger (ECL) under Rule 86A of CGST Rules, 2017 was procedurally invalid. The order was quashed due to absence of pre-decisional hearing, lack of independent reasons to believe, and reliance on borrowed satisfaction from enforcement authorities. The court directed immediate unblocking of petitioner's ECL, emphasizing principles of natural justice. The impugned order was deemed illegal and arbitrary, thus rendering the ECL blockage null and void. Respondents were mandated to restore the petitioner's ECL forthwith, enabling normal tax compliance proceedings.
HC ruled that blocking of Electronic Credit Ledger (ECL) under Rule 86A of CGST Rules, 2017 was procedurally invalid. The order was quashed due to absence of pre-decisional hearing, lack of independent reasons to believe, and reliance on borrowed satisfaction from enforcement authorities. The court directed immediate unblocking of petitioner's ECL, emphasizing principles of natural justice. The impugned order was deemed illegal and arbitrary, thus rendering the ECL blockage null and void. Respondents were mandated to restore the petitioner's ECL forthwith, enabling normal tax compliance proceedings.
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