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 dismissed the writ petition for lack of maintainability, holding that the petitioner lacked locus standi to invoke Article 226 jurisdiction. Although the petitioner filed complaints leading to notices by GST and Income Tax authorities, no personal legal injury or infringement of rights was demonstrated. The Court emphasized that Article 226 jurisdiction requires the petitioner to have a personal or individual right affected, except in habeas corpus or quo warranto petitions. Since the petitioner neither suffered legal grievance nor was aggrieved by official inaction, he could not claim to be a person aggrieved entitled to seek mandamus. Consequently, the petition was dismissed as not maintainable for failure to establish a vested right or personal harm.
The HC dismissed the writ petition for lack of maintainability, holding that the petitioner lacked locus standi to invoke Article 226 jurisdiction. Although the petitioner filed complaints leading to notices by GST and Income Tax authorities, no personal legal injury or infringement of rights was demonstrated. The Court emphasized that Article 226 jurisdiction requires the petitioner to have a personal or individual right affected, except in habeas corpus or quo warranto petitions. Since the petitioner neither suffered legal grievance nor was aggrieved by official inaction, he could not claim to be a person aggrieved entitled to seek mandamus. Consequently, the petition was dismissed as not maintainable for failure to establish a vested right or personal harm.
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