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 determined that the imposition of penalty under Section 122(2)(b) of the GST Act, 2017 was procedurally flawed due to non-compliance with Rule 142(1A) regarding communication of tax details. The court found the tax liability determination for July 2017 to March 2019 legally erroneous. As an interim measure, the court directed the petitioner to deposit 20% of the tax amount determined in the original order within two weeks, with a consequent restraint on coercive recovery measures by the tax authorities pending further adjudication.
HC determined that the imposition of penalty under Section 122(2)(b) of the GST Act, 2017 was procedurally flawed due to non-compliance with Rule 142(1A) regarding communication of tax details. The court found the tax liability determination for July 2017 to March 2019 legally erroneous. As an interim measure, the court directed the petitioner to deposit 20% of the tax amount determined in the original order within two weeks, with a consequent restraint on coercive recovery measures by the tax authorities pending further adjudication.
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