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 set aside an appellate authority's order under Section 107 of the WBGST/CGST Act, 2017, which had rejected petitioner's appeal for non-payment of pre-deposit amount. Despite petitioner having statutory remedy before appellate tribunal, the HC noted the tribunal remains unconstituted. Considering petitioner had already deposited equivalent pre-deposit amount, the HC deemed it prudent to remand the matter to appellate authority for decision on merits. The appellate order dated 29th November, 2024 was set aside and petition disposed of by way of remand, allowing fresh consideration of the substantive issues.
The HC set aside an appellate authority's order under Section 107 of the WBGST/CGST Act, 2017, which had rejected petitioner's appeal for non-payment of pre-deposit amount. Despite petitioner having statutory remedy before appellate tribunal, the HC noted the tribunal remains unconstituted. Considering petitioner had already deposited equivalent pre-deposit amount, the HC deemed it prudent to remand the matter to appellate authority for decision on merits. The appellate order dated 29th November, 2024 was set aside and petition disposed of by way of remand, allowing fresh consideration of the substantive issues.
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