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 petition challenging simultaneous GST proceedings, quashing the SCN issued by state authorities under Section 70 and Section 74. The court directed the petitioner to file reply before the central GST authority, considering recent circulars and precedential judgments. The key relief includes: (i) quashing of impugned SCN, (ii) liberty to file comprehensive reply, and (iii) mandate for respondent to reconsider claims in accordance with recent GST circulars and judicial interpretations, particularly regarding input tax credit and valuation for tax payment.
HC allows petition challenging simultaneous GST proceedings, quashing the SCN issued by state authorities under Section 70 and Section 74. The court directed the petitioner to file reply before the central GST authority, considering recent circulars and precedential judgments. The key relief includes: (i) quashing of impugned SCN, (ii) liberty to file comprehensive reply, and (iii) mandate for respondent to reconsider claims in accordance with recent GST circulars and judicial interpretations, particularly regarding input tax credit and valuation for tax payment.
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