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 challenging tender conditions related to GST inclusion. The court held that the tender document clearly stipulated rates should be inclusive of taxes, and after GST regime introduction, 'sales tax' must be interpreted as GST. The petitioner cannot challenge tender terms post-contract execution after voluntarily participating in the bidding process. The court emphasized that tender conditions, once accepted and acted upon, are binding and cannot be unilaterally varied by a bidder. The appeal was dismissed, upholding the principle that bidders cannot seek additional payments when tender documents explicitly require tax-inclusive rates.
HC dismissed the writ petition challenging tender conditions related to GST inclusion. The court held that the tender document clearly stipulated rates should be inclusive of taxes, and after GST regime introduction, 'sales tax' must be interpreted as GST. The petitioner cannot challenge tender terms post-contract execution after voluntarily participating in the bidding process. The court emphasized that tender conditions, once accepted and acted upon, are binding and cannot be unilaterally varied by a bidder. The appeal was dismissed, upholding the principle that bidders cannot seek additional payments when tender documents explicitly require tax-inclusive rates.
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