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 procedural matter concerning natural justice principles, specifically addressing communication deficiencies in legal proceedings. The court mandated the Registry to implement communication protocols for efficient case processing within the CGST Department. Key directives included: deputizing two officers from CGST and CX Delhi Zone for immediate instructions, publishing email addresses of Commissionerates in cause lists, and requiring specific Commissionerate names in writ petitions. The court emphasized improved communication mechanisms to enhance legal service delivery and transparency. Petition was disposed of with procedural recommendations for future case management.
HC adjudicated a procedural matter concerning natural justice principles, specifically addressing communication deficiencies in legal proceedings. The court mandated the Registry to implement communication protocols for efficient case processing within the CGST Department. Key directives included: deputizing two officers from CGST and CX Delhi Zone for immediate instructions, publishing email addresses of Commissionerates in cause lists, and requiring specific Commissionerate names in writ petitions. The court emphasized improved communication mechanisms to enhance legal service delivery and transparency. Petition was disposed of with procedural recommendations for future case management.
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