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 allowed the petition challenging goods seizure during transit. The court found no legal basis for seizure under GST Act, as authorities failed to establish tax evasion intent or document discrepancies. The goods were being transported from Meerut to Kanpur, intercepted at Basti solely due to an alternate route, without any substantive evidence of procedural violations. The court emphasized that absent specific statutory provisions mandating route declaration, the seizure was unwarranted. All accompanying documents were verified as genuine in quality and quantity, further invalidating the administrative action. The ruling underscores procedural propriety and protects taxpayer rights against arbitrary administrative interventions.
HC allowed the petition challenging goods seizure during transit. The court found no legal basis for seizure under GST Act, as authorities failed to establish tax evasion intent or document discrepancies. The goods were being transported from Meerut to Kanpur, intercepted at Basti solely due to an alternate route, without any substantive evidence of procedural violations. The court emphasized that absent specific statutory provisions mandating route declaration, the seizure was unwarranted. All accompanying documents were verified as genuine in quality and quantity, further invalidating the administrative action. The ruling underscores procedural propriety and protects taxpayer rights against arbitrary administrative interventions.
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