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 irregularities in service of show cause notice (SCN). The court found that a consolidated SCN was issued across multiple financial years under Section 74 of the Central Goods and Service Tax Act, 2017, addressing short payment and input tax credit issues. Despite no prior hearing notice to the Petitioner, the court held that the Petitioner retains the right to submit arguments and challenge the impugned order. The petition was disposed of, allowing the Petitioner procedural opportunities to present their case in subsequent proceedings.
HC adjudicated a tax dispute involving procedural irregularities in service of show cause notice (SCN). The court found that a consolidated SCN was issued across multiple financial years under Section 74 of the Central Goods and Service Tax Act, 2017, addressing short payment and input tax credit issues. Despite no prior hearing notice to the Petitioner, the court held that the Petitioner retains the right to submit arguments and challenge the impugned order. The petition was disposed of, allowing the Petitioner procedural opportunities to present their case in subsequent proceedings.
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