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 remanded the GST-related appeal back to the Appellate Authority due to procedural irregularities in order notification. The court directed that the original show-cause notice and adjudication order be reissued in the petitioner's name, and mandated uploading of all related orders on the petitioner's portal. The appeal will be reassessed by a different officer to ensure fair review, addressing the technical deficiencies in the initial proceedings without prejudicing the petitioner's substantive rights.
HC remanded the GST-related appeal back to the Appellate Authority due to procedural irregularities in order notification. The court directed that the original show-cause notice and adjudication order be reissued in the petitioner's name, and mandated uploading of all related orders on the petitioner's portal. The appeal will be reassessed by a different officer to ensure fair review, addressing the technical deficiencies in the initial proceedings without prejudicing the petitioner's substantive rights.
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