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 examined the validity of recovery proceedings in light of the non-constitution of the GST Appellate Tribunal and compliance with Section 107(6) of the CGST Act, alongside the applicability of Circular No. 224/18/2024 GST dated 11th July, 2024. The petitioner had availed benefits under the said circular and deposited 10% of the demanded amount. The court held that since the petitioner complied with the prescribed guidelines by making the requisite deposit, the recovery notices issued on 28th February, 19th March, and 25th March 2025 were quashed. The petition was accordingly disposed of.
The HC examined the validity of recovery proceedings in light of the non-constitution of the GST Appellate Tribunal and compliance with Section 107(6) of the CGST Act, alongside the applicability of Circular No. 224/18/2024 GST dated 11th July, 2024. The petitioner had availed benefits under the said circular and deposited 10% of the demanded amount. The court held that since the petitioner complied with the prescribed guidelines by making the requisite deposit, the recovery notices issued on 28th February, 19th March, and 25th March 2025 were quashed. The petition was accordingly disposed of.
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