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 adjudicated a challenge to the First Appellate Authority's order mandating a deposit for stay of the impugned tax order. It recognized a Central revenue notification reducing the deposit requirement to 10% of the disputed tax. The State revenue issued a corresponding notification aligning with this reduction. Consequently, the HC modified the earlier order, directing the petitioner to deposit 10% of the remaining disputed tax to maintain the stay. The petitioner's submission regarding the reduced deposit was accepted, and the writ petition was disposed of accordingly, with the stay contingent upon compliance with the revised deposit condition.
The HC adjudicated a challenge to the First Appellate Authority's order mandating a deposit for stay of the impugned tax order. It recognized a Central revenue notification reducing the deposit requirement to 10% of the disputed tax. The State revenue issued a corresponding notification aligning with this reduction. Consequently, the HC modified the earlier order, directing the petitioner to deposit 10% of the remaining disputed tax to maintain the stay. The petitioner's submission regarding the reduced deposit was accepted, and the writ petition was disposed of accordingly, with the stay contingent upon compliance with the revised deposit condition.
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