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 allows taxpayer's challenge to tax determination order under CGST/KSGST Acts. The court found that service of show cause notice and tax order through an additional notices tab did not constitute proper legal service. The HC held that the appellate authority improperly dismissed the appeal on technical delay grounds. Consequently, the court directed the appellate authority to review the appeal on substantive merits, effectively treating the appeal as timely filed and providing procedural relief to the taxpayer.
HC allows taxpayer's challenge to tax determination order under CGST/KSGST Acts. The court found that service of show cause notice and tax order through an additional notices tab did not constitute proper legal service. The HC held that the appellate authority improperly dismissed the appeal on technical delay grounds. Consequently, the court directed the appellate authority to review the appeal on substantive merits, effectively treating the appeal as timely filed and providing procedural relief to the taxpayer.
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