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 petition challenging show cause notice and consequent order along with notifications 9/2023-Central Tax, 56/2023-Central Tax, and 56/2023-State Tax. Petitioner alleged impugned order was passed hastily without considering their reply and documents, violating natural justice principles. Court examined submissions and impugned order, finding it was passed after due consideration of petitioner's reply. HC determined the order did not warrant judicial interference and directed petitioner to pursue remedy before appellate authority. Court granted extension until 15th July 2025 for filing appeal under Section 107 of Central Goods and Service Tax Act 2017. Petition disposed of with direction to exhaust statutory appellate remedy.
HC dismissed the petition challenging show cause notice and consequent order along with notifications 9/2023-Central Tax, 56/2023-Central Tax, and 56/2023-State Tax. Petitioner alleged impugned order was passed hastily without considering their reply and documents, violating natural justice principles. Court examined submissions and impugned order, finding it was passed after due consideration of petitioner's reply. HC determined the order did not warrant judicial interference and directed petitioner to pursue remedy before appellate authority. Court granted extension until 15th July 2025 for filing appeal under Section 107 of Central Goods and Service Tax Act 2017. Petition disposed of with direction to exhaust statutory appellate remedy.
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