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 dismissed the writ petition challenging a GST demand notice under Section 73 of the GST Act. The court found no merit in the petitioner's challenge, noting the delayed response to the show cause notice, lack of valid explanation for delay, and failure to pursue alternative appellate remedies. The court held that the petitioner cannot frustrate the adjudicatory process by belatedly approaching the court after failing to respond within the prescribed timeline, and rejected the contention of lack of hearing opportunity.
HC dismissed the writ petition challenging a GST demand notice under Section 73 of the GST Act. The court found no merit in the petitioner's challenge, noting the delayed response to the show cause notice, lack of valid explanation for delay, and failure to pursue alternative appellate remedies. The court held that the petitioner cannot frustrate the adjudicatory process by belatedly approaching the court after failing to respond within the prescribed timeline, and rejected the contention of lack of hearing opportunity.
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