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 allowed the writ petition concerning tax return discrepancies between GSTR-1 and GSTR 3B. The court directed tax authorities to rectify the GSTR 3B form in alignment with GSTR-1 contents within one month, mandating the petitioner to submit a manual application. The authorities were further instructed to address any consequential grievances within two months, effectively permitting correction of administrative errors in tax documentation and providing procedural relief to the taxpayer.
HC allowed the writ petition concerning tax return discrepancies between GSTR-1 and GSTR 3B. The court directed tax authorities to rectify the GSTR 3B form in alignment with GSTR-1 contents within one month, mandating the petitioner to submit a manual application. The authorities were further instructed to address any consequential grievances within two months, effectively permitting correction of administrative errors in tax documentation and providing procedural relief to the taxpayer.
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