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 quashed the provisional attachment of petitioner's bank account under Section 83 of CGST Act, 2017. The court found the respondents' action arbitrary, lacking substantive evidence of revenue risk. Despite petitioner's non-cooperation in show cause proceedings, the attachment was deemed invalid as the authorities failed to demonstrate a reasonable apprehension of revenue default. The court emphasized that provisional attachment requires cogent material basis and cannot be justified by mere procedural non-compliance. The impugned order was set aside, with directions to immediately de-freeze the petitioner's bank account, reinforcing the principle that administrative powers must be exercised with due diligence and proportionality.
HC quashed the provisional attachment of petitioner's bank account under Section 83 of CGST Act, 2017. The court found the respondents' action arbitrary, lacking substantive evidence of revenue risk. Despite petitioner's non-cooperation in show cause proceedings, the attachment was deemed invalid as the authorities failed to demonstrate a reasonable apprehension of revenue default. The court emphasized that provisional attachment requires cogent material basis and cannot be justified by mere procedural non-compliance. The impugned order was set aside, with directions to immediately de-freeze the petitioner's bank account, reinforcing the principle that administrative powers must be exercised with due diligence and proportionality.
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