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 held that petitioner must comply with Circular No. 224/18/2024-GST by making pre-deposit under Section 112(8) of CGST Act and filing a mandatory undertaking/declaration with proper jurisdictional officer. Petitioner demonstrated willingness to submit required documentation. Writ petition disposed of, granting liberty to petitioner to file the requisite undertaking/declaration in accordance with the circular's stipulations, thereby preserving potential appellate rights pending Appellate Tribunal's formal constitution.
HC held that petitioner must comply with Circular No. 224/18/2024-GST by making pre-deposit under Section 112(8) of CGST Act and filing a mandatory undertaking/declaration with proper jurisdictional officer. Petitioner demonstrated willingness to submit required documentation. Writ petition disposed of, granting liberty to petitioner to file the requisite undertaking/declaration in accordance with the circular's stipulations, thereby preserving potential appellate rights pending Appellate Tribunal's formal constitution.
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