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 dismissed the writ petition challenging the issuance of GST show cause notices (FORM DRC-01 and DRC-02). The court held that when multiple parties are involved in complex transactions, the show cause notice providing computation details for each noticee is sufficient. The court declined to intervene in ongoing adjudication proceedings, emphasizing the limited scope of writ jurisdiction under Article 226. The statutory proceedings against the petitioners shall continue in accordance with established legal protocols, with the court refraining from examining the veracity of departmental statements at this stage.
HC dismissed the writ petition challenging the issuance of GST show cause notices (FORM DRC-01 and DRC-02). The court held that when multiple parties are involved in complex transactions, the show cause notice providing computation details for each noticee is sufficient. The court declined to intervene in ongoing adjudication proceedings, emphasizing the limited scope of writ jurisdiction under Article 226. The statutory proceedings against the petitioners shall continue in accordance with established legal protocols, with the court refraining from examining the veracity of departmental statements at this stage.
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