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 the non-constitution of the GST Tribunal and the petitioner's request for a stay on recovery proceedings pending appeal. The petitioner had already deposited 10% of the tax demand and agreed to deposit an additional 10% of the remaining amount. In light of the Government of India's circular and the petitioner's undertaking, the court held that the requirements under Section 112(8) of the CGST Act were met. Consequently, recovery of the remaining confirmed demand is stayed pursuant to Section 112(9) of the CGST Act upon the petitioner's compliance with the prescribed pre-deposit conditions. No further directions were deemed necessary, and the writ petition was disposed of accordingly.
The HC disposed of the writ petition concerning the non-constitution of the GST Tribunal and the petitioner's request for a stay on recovery proceedings pending appeal. The petitioner had already deposited 10% of the tax demand and agreed to deposit an additional 10% of the remaining amount. In light of the Government of India's circular and the petitioner's undertaking, the court held that the requirements under Section 112(8) of the CGST Act were met. Consequently, recovery of the remaining confirmed demand is stayed pursuant to Section 112(9) of the CGST Act upon the petitioner's compliance with the prescribed pre-deposit conditions. No further directions were deemed necessary, and the writ petition was disposed of accordingly.
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