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 writ petition concerning attachment and short-payment of Rs.35,59,067. The petitioner admitted liability for the sum and requested monthly installments, but the second respondent failed to consider this representation dated 26.05.2025. The court declined to intervene against garnishee proceedings dated 15.04.2025 given the admitted liability. However, the HC directed the second respondent to consider and pass orders on the petitioner's representation for 24 equal monthly installments within three weeks from receipt of the order, recognizing the respondent's duty to consider such applications expeditiously and protect the petitioner's interests.
The HC disposed of the writ petition concerning attachment and short-payment of Rs.35,59,067. The petitioner admitted liability for the sum and requested monthly installments, but the second respondent failed to consider this representation dated 26.05.2025. The court declined to intervene against garnishee proceedings dated 15.04.2025 given the admitted liability. However, the HC directed the second respondent to consider and pass orders on the petitioner's representation for 24 equal monthly installments within three weeks from receipt of the order, recognizing the respondent's duty to consider such applications expeditiously and protect the petitioner's interests.
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