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...
The HC quashed orders blocking petitioner's Electronic Credit Ledger and provisionally attaching bank account under Rule 86A of Central Goods and Services Tax Rules, 2017. The court held that respondents failed to provide pre-decisional hearing, violating principles of natural justice, and lacked independent cogent reasons to believe as required under Rule 86A. The impugned orders relied on borrowed satisfaction from enforcement authority reports, which is impermissible in law. The court found the orders illegal and arbitrary for non-compliance with mandatory procedural and substantive requirements. Respondents were directed to immediately unblock petitioner's Electronic Credit Ledger upon receipt of the order to enable filing of returns. Petition allowed.
The HC quashed orders blocking petitioner's Electronic Credit Ledger and provisionally attaching bank account under Rule 86A of Central Goods and Services Tax Rules, 2017. The court held that respondents failed to provide pre-decisional hearing, violating principles of natural justice, and lacked independent cogent reasons to believe as required under Rule 86A. The impugned orders relied on borrowed satisfaction from enforcement authority reports, which is impermissible in law. The court found the orders illegal and arbitrary for non-compliance with mandatory procedural and substantive requirements. Respondents were directed to immediately unblock petitioner's Electronic Credit Ledger upon receipt of the order to enable filing of returns. Petition allowed.
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