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 detention of goods and levy of tax and penalty under CGST Act. Court held the impugned order demonstrated due application of mind, proper consideration of factual matrix and petitioner's submissions, with cogent reasons provided. No procedural impropriety, manifest illegality, or violation of natural justice principles established. Authorities acted within statutory powers under Section 129(3) CGST Act with reasonable appreciation of evidence. Court emphasized judicial review under Article 226 does not permit reappreciation of evidence or substitution of factual findings when efficacious alternative remedy exists. Petition found devoid of merit, dismissed with liberty to pursue statutory appeal under Section 107 CGST Act.
HC dismissed the writ petition challenging detention of goods and levy of tax and penalty under CGST Act. Court held the impugned order demonstrated due application of mind, proper consideration of factual matrix and petitioner's submissions, with cogent reasons provided. No procedural impropriety, manifest illegality, or violation of natural justice principles established. Authorities acted within statutory powers under Section 129(3) CGST Act with reasonable appreciation of evidence. Court emphasized judicial review under Article 226 does not permit reappreciation of evidence or substitution of factual findings when efficacious alternative remedy exists. Petition found devoid of merit, dismissed with liberty to pursue statutory appeal under Section 107 CGST Act.
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