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 disposed of the petitioner's challenge to an assessment order after the petitioner discharged tax liability and interest under an amnesty scheme settlement. The court balanced revenue and petitioner interests by remitting the matter to the first respondent for reconsideration of the penalty imposition under Section 74 of the GST enactment only. While the petitioner had settled the primary tax liability and interest components through the amnesty scheme, the court directed fresh consideration specifically regarding the penalty component, effectively providing partial relief to the petitioner while protecting revenue interests in the underlying tax assessment.
The HC disposed of the petitioner's challenge to an assessment order after the petitioner discharged tax liability and interest under an amnesty scheme settlement. The court balanced revenue and petitioner interests by remitting the matter to the first respondent for reconsideration of the penalty imposition under Section 74 of the GST enactment only. While the petitioner had settled the primary tax liability and interest components through the amnesty scheme, the court directed fresh consideration specifically regarding the penalty component, effectively providing partial relief to the petitioner while protecting revenue interests in the underlying tax assessment.
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