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 modified its prior interim order regarding CGST Act amendment, reducing the mandatory deposit from twenty percent to ten percent as per the Finance (No. 2) Act, 2024. The court interpreted Section 112(8) and Section 143, concluding that the statutory amendment directly impacts the interim deposit requirement. Consequently, the original direction for twenty percent deposit shall now be construed as a ten percent deposit, effectively aligning with the recent legislative modification. Application disposed of with consequential relief.
HC modified its prior interim order regarding CGST Act amendment, reducing the mandatory deposit from twenty percent to ten percent as per the Finance (No. 2) Act, 2024. The court interpreted Section 112(8) and Section 143, concluding that the statutory amendment directly impacts the interim deposit requirement. Consequently, the original direction for twenty percent deposit shall now be construed as a ten percent deposit, effectively aligning with the recent legislative modification. Application disposed of with consequential relief.
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