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 rejected the petition challenging a GST show cause notice, holding that an inadvertent misdescription in document title does not invalidate its substantive content. The court found the document clearly identifiable as a valid Section 73 notice through portal description, watermarks, and accompanying context. The ex-parte order was deemed sustainable, emphasizing that procedural errors do not negate the fundamental legal communication. The petitioner's attempt to challenge the notice based on title discrepancy was considered frivolous. Consequently, the court upheld the departmental proceedings and disposed of the petition, affirming the tax authority's right to issue notices despite minor formal inconsistencies.
HC rejected the petition challenging a GST show cause notice, holding that an inadvertent misdescription in document title does not invalidate its substantive content. The court found the document clearly identifiable as a valid Section 73 notice through portal description, watermarks, and accompanying context. The ex-parte order was deemed sustainable, emphasizing that procedural errors do not negate the fundamental legal communication. The petitioner's attempt to challenge the notice based on title discrepancy was considered frivolous. Consequently, the court upheld the departmental proceedings and disposed of the petition, affirming the tax authority's right to issue notices despite minor formal inconsistencies.
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