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 blocking of electronic credit ledger under Rule 86A of CGST Rules. The court found the impugned order invalid due to lack of pre-decisional hearing and absence of cogent reasons. The order invoking Section 86A was quashed, directing immediate unblocking of the electronic credit ledger. Respondents retain liberty to proceed against petitioner in accordance with law. Petitioner mandated to appear before respondent on specified date, with automatic revival of proceedings if non-compliance occurs.
HC allows petition challenging blocking of electronic credit ledger under Rule 86A of CGST Rules. The court found the impugned order invalid due to lack of pre-decisional hearing and absence of cogent reasons. The order invoking Section 86A was quashed, directing immediate unblocking of the electronic credit ledger. Respondents retain liberty to proceed against petitioner in accordance with law. Petitioner mandated to appear before respondent on specified date, with automatic revival of proceedings if non-compliance occurs.
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