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 adjudicated a tax dispute involving procedural challenges to bank account attachment under CGST Act. The court determined that subsequent appellate proceedings and Supreme Court's prior intervention rendered the original bank account freezing order unsustainable. Given the petitioner's utilization of statutory appellate remedies under Section 107 and the progression of underlying show cause notice proceedings, the court ruled to automatically lift the bank account attachment order dated 28th May, 2024. The petition was consequently disposed of, effectively restoring the petitioner's financial operational capacity.
HC adjudicated a tax dispute involving procedural challenges to bank account attachment under CGST Act. The court determined that subsequent appellate proceedings and Supreme Court's prior intervention rendered the original bank account freezing order unsustainable. Given the petitioner's utilization of statutory appellate remedies under Section 107 and the progression of underlying show cause notice proceedings, the court ruled to automatically lift the bank account attachment order dated 28th May, 2024. The petition was consequently disposed of, effectively restoring the petitioner's financial operational capacity.
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