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 held that the assessment order dated 13.12.2023 was not time-barred due to successive government notifications extending the statutory time limit for GST assessment proceedings for FY 2017-18. Specifically, notifications dated 21.07.2022 and 24.04.2023 extended the time limit to 31.12.2023, rendering the impugned order legally valid. Since the order was passed within the extended timeline and the notifications were not challenged, the writ petition was deemed non-maintainable, with the statutory remedy of appeal being the appropriate recourse. Consequently, the HC dismissed the petition.
HC held that the assessment order dated 13.12.2023 was not time-barred due to successive government notifications extending the statutory time limit for GST assessment proceedings for FY 2017-18. Specifically, notifications dated 21.07.2022 and 24.04.2023 extended the time limit to 31.12.2023, rendering the impugned order legally valid. Since the order was passed within the extended timeline and the notifications were not challenged, the writ petition was deemed non-maintainable, with the statutory remedy of appeal being the appropriate recourse. Consequently, the HC dismissed the petition.
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