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 granted petitioner liberty to file appeal under Section 107 of CGST Act by 15th July, 2025, with mandatory pre-deposit. The court permitted appellate remedy to be adjudicated on merits without limitation bar. The pending decision in Quest Infotech case regarding consolidated show cause notice across multiple financial years shall potentially bind appellate proceedings. The court emphasized procedural compliance and principles of natural justice while addressing fraudulent ITC availment and goods-less invoice issues.
HC granted petitioner liberty to file appeal under Section 107 of CGST Act by 15th July, 2025, with mandatory pre-deposit. The court permitted appellate remedy to be adjudicated on merits without limitation bar. The pending decision in Quest Infotech case regarding consolidated show cause notice across multiple financial years shall potentially bind appellate proceedings. The court emphasized procedural compliance and principles of natural justice while addressing fraudulent ITC availment and goods-less invoice issues.
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