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 tax credit assessment, finding no violation of natural justice. The court noted petitioners failed to substantively contest the main issue of goods supply and input tax credit. While rejecting procedural challenges regarding relied upon documents (RUDs), the HC granted liberty to file an appeal under Section 107 of CGST Act by 15th July, 2025, with mandatory pre-deposit, ensuring merits-based appellate review. The decision emphasizes procedural compliance and substantive argumentation in tax dispute resolution.
HC dismissed the writ petition challenging tax credit assessment, finding no violation of natural justice. The court noted petitioners failed to substantively contest the main issue of goods supply and input tax credit. While rejecting procedural challenges regarding relied upon documents (RUDs), the HC granted liberty to file an appeal under Section 107 of CGST Act by 15th July, 2025, with mandatory pre-deposit, ensuring merits-based appellate review. The decision emphasizes procedural compliance and substantive argumentation in tax dispute resolution.
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