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 dismissed the petition challenging Policy Circular No. 06/2018 and subsequent Show Cause Notice as premature. The court held that the Show Cause Notice was a consequential proceeding related to an original order by DGFT, and therefore, premature judicial intervention was unwarranted. No interim relief was granted, and the petition was dismissed in limine, leaving the petitioner free to challenge the original DGFT order through appropriate legal channels.
HC dismissed the petition challenging Policy Circular No. 06/2018 and subsequent Show Cause Notice as premature. The court held that the Show Cause Notice was a consequential proceeding related to an original order by DGFT, and therefore, premature judicial intervention was unwarranted. No interim relief was granted, and the petition was dismissed in limine, leaving the petitioner free to challenge the original DGFT order through appropriate legal channels.
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