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 set aside the impugned suo motu order passed under Section 108 of the Chhattisgarh GST Act, 2017, on grounds of violation of natural justice and lack of jurisdiction at the time of issuance. The Court held that the revisional authority was not validly empowered to pass the order on 01.06.2019, as the relevant notification authorizing such authority was issued only on 07.08.2020. Furthermore, the order failed to provide any cogent reasons or record the requisite satisfaction for exercising revisionary powers, rendering it unsustainable. Consequently, the HC directed the concerned authority to discontinue the revision proceedings forthwith and allowed the petition.
The HC set aside the impugned suo motu order passed under Section 108 of the Chhattisgarh GST Act, 2017, on grounds of violation of natural justice and lack of jurisdiction at the time of issuance. The Court held that the revisional authority was not validly empowered to pass the order on 01.06.2019, as the relevant notification authorizing such authority was issued only on 07.08.2020. Furthermore, the order failed to provide any cogent reasons or record the requisite satisfaction for exercising revisionary powers, rendering it unsustainable. Consequently, the HC directed the concerned authority to discontinue the revision proceedings forthwith and allowed the petition.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4798
Join Channel
TaxTMI 
