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 found SCNs and affidavits to be forged, with fictitious petitioners submitting fabricated documents challenging GST registration cancellation. Court directed DGGI officials to conduct thorough investigation and file complaint with Crime Branch within one week. Registrar General instructed to lodge complaint against petitioners under relevant sections of Bharatiya Nyaya Sanhita and Bharatiya Nagarik Suraksha Sanhita for forgery and fabrication. Non-bailable warrants discharged subject to petitioner's undertaking to cooperate with DGGI investigation. Petition dismissed, with court emphasizing need for comprehensive legal action against fraudulent documentation.
HC found SCNs and affidavits to be forged, with fictitious petitioners submitting fabricated documents challenging GST registration cancellation. Court directed DGGI officials to conduct thorough investigation and file complaint with Crime Branch within one week. Registrar General instructed to lodge complaint against petitioners under relevant sections of Bharatiya Nyaya Sanhita and Bharatiya Nagarik Suraksha Sanhita for forgery and fabrication. Non-bailable warrants discharged subject to petitioner's undertaking to cooperate with DGGI investigation. Petition dismissed, with court emphasizing need for comprehensive legal action against fraudulent documentation.
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