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 allowed petitioner to file reply to six-month-old show cause notice challenging GST registration cancellation under Rule 21(b) for issuing invoices without actual supply of goods or services. Court directed petitioner to disclose any pending CGST proceedings including input tax credit matters in reply by 1st July 2025. DGST must decide within one month of reply submission and may verify pending CGST proceedings against petitioner. Petition disposed of with directions for administrative resolution rather than judicial determination of substantive GST violation allegations.
HC allowed petitioner to file reply to six-month-old show cause notice challenging GST registration cancellation under Rule 21(b) for issuing invoices without actual supply of goods or services. Court directed petitioner to disclose any pending CGST proceedings including input tax credit matters in reply by 1st July 2025. DGST must decide within one month of reply submission and may verify pending CGST proceedings against petitioner. Petition disposed of with directions for administrative resolution rather than judicial determination of substantive GST violation allegations.
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