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 the impugned order and remitted the matter to respondent No.5 for fresh reconsideration following subsequent developments where proceedings against the petitioner were dropped for tax period 2020-21. The court found the impugned notifications dated 28.12.2023 and 29.12.2023 required examination regarding their validity under Section 168A read with Section 73 of CGST/KGST Act, 2017, and applicability of Circular No. 219/13/2024-GST. The petition was allowed by way of remand, directing respondent No.5 to reconsider the matter afresh within stipulated timeframe in accordance with law, bearing in mind the Form GST DRC-05 order dated 28.02.2025.
The HC set aside the impugned order and remitted the matter to respondent No.5 for fresh reconsideration following subsequent developments where proceedings against the petitioner were dropped for tax period 2020-21. The court found the impugned notifications dated 28.12.2023 and 29.12.2023 required examination regarding their validity under Section 168A read with Section 73 of CGST/KGST Act, 2017, and applicability of Circular No. 219/13/2024-GST. The petition was allowed by way of remand, directing respondent No.5 to reconsider the matter afresh within stipulated timeframe in accordance with law, bearing in mind the Form GST DRC-05 order dated 28.02.2025.
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