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 writ petition in part, finding that the notice issued under Section 73 of CGST Act, 2017 did not comply with statutory requirements for providing thirty days' response time. The court set aside the impugned actions dated 30.11.2023 and remanded the matter to the authority to issue a corrigendum to the 29.09.2023 notice, extending the reply and hearing timelines in strict accordance with Section 73(8). The authority must complete this exercise within three months from the order date, with remaining contentions left open for future adjudication.
HC allowed the writ petition in part, finding that the notice issued under Section 73 of CGST Act, 2017 did not comply with statutory requirements for providing thirty days' response time. The court set aside the impugned actions dated 30.11.2023 and remanded the matter to the authority to issue a corrigendum to the 29.09.2023 notice, extending the reply and hearing timelines in strict accordance with Section 73(8). The authority must complete this exercise within three months from the order date, with remaining contentions left open for future adjudication.
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