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 found multiple GST notifications challenging deadline extensions during COVID-19 potentially procedurally defective. While the core validity issue is pending before SC, the court provisionally recommended case-specific relief approaches. The HC suggested allowing petitioners opportunities to present arguments, pursue appellate remedies, and challenge ex-parte orders across six identified case categories. Parties were directed to provide further instructions, with potential interim relief mechanisms to be finalized, recognizing potential procedural irregularities in the original notifications without definitively ruling on their ultimate legal standing.
HC found multiple GST notifications challenging deadline extensions during COVID-19 potentially procedurally defective. While the core validity issue is pending before SC, the court provisionally recommended case-specific relief approaches. The HC suggested allowing petitioners opportunities to present arguments, pursue appellate remedies, and challenge ex-parte orders across six identified case categories. Parties were directed to provide further instructions, with potential interim relief mechanisms to be finalized, recognizing potential procedural irregularities in the original notifications without definitively ruling on their ultimate legal standing.
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