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 dismissed the writ petition, declining to adjudicate the GST liability dispute. The court found significant discrepancies in the petitioner's self-declared turnover values across different documents and inconsistent financial reporting. Citing SC precedent, the court held that the petitioner must first exhaust the alternative statutory remedy by filing an appeal before the Commissioner (Appeals) under Section 107 of the GST Act. The petition was disposed of without examining the substantive merits, directing the petitioner to pursue the prescribed administrative appellate mechanism.
HC dismissed the writ petition, declining to adjudicate the GST liability dispute. The court found significant discrepancies in the petitioner's self-declared turnover values across different documents and inconsistent financial reporting. Citing SC precedent, the court held that the petitioner must first exhaust the alternative statutory remedy by filing an appeal before the Commissioner (Appeals) under Section 107 of the GST Act. The petition was disposed of without examining the substantive merits, directing the petitioner to pursue the prescribed administrative appellate mechanism.
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