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 determined that the petitioner may file two appeals challenging orders dated 28th January 2025 and 1st February 2025 under Section 107 of CGST Act, 2017. Pre-deposit shall be made only for the total amount of Rs. 81,41,737/- from the Order-in-Original dated 28th January 2025, comprising Rs. 64,31,703/- and Rs. 17,10,034/-. No additional pre-deposit is required for the Order-in-Original dated 1st February 2025. Appeals must be filed by 15th July 2025, and shall not be dismissed on grounds of limitation or lack of pre-deposit, but adjudicated on merits.
HC determined that the petitioner may file two appeals challenging orders dated 28th January 2025 and 1st February 2025 under Section 107 of CGST Act, 2017. Pre-deposit shall be made only for the total amount of Rs. 81,41,737/- from the Order-in-Original dated 28th January 2025, comprising Rs. 64,31,703/- and Rs. 17,10,034/-. No additional pre-deposit is required for the Order-in-Original dated 1st February 2025. Appeals must be filed by 15th July 2025, and shall not be dismissed on grounds of limitation or lack of pre-deposit, but adjudicated on merits.
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