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 quashed the impugned order rejecting petitioner's rectification application due to procedural error. The revenue authority incorrectly stated petitioner failed to reply to show cause notice, despite petitioner's timely response dated 22.01.2025 being duly acknowledged in Form GST DRC 06. Court found petitioner established grounds for judicial interference as the order contained factual inaccuracy regarding non-response. Matter remitted to respondent authority with directions to pass fresh order on merits within three months, ensuring petitioner's reply is considered and hearing opportunity provided. Petition allowed by way of remand, emphasizing adherence to principles of natural justice in administrative proceedings.
HC quashed the impugned order rejecting petitioner's rectification application due to procedural error. The revenue authority incorrectly stated petitioner failed to reply to show cause notice, despite petitioner's timely response dated 22.01.2025 being duly acknowledged in Form GST DRC 06. Court found petitioner established grounds for judicial interference as the order contained factual inaccuracy regarding non-response. Matter remitted to respondent authority with directions to pass fresh order on merits within three months, ensuring petitioner's reply is considered and hearing opportunity provided. Petition allowed by way of remand, emphasizing adherence to principles of natural justice in administrative proceedings.
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