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 upheld the impugned order confirming tax liability on the deceased individual, rejecting the limitation plea under Section 74(10) of the GST Act by applying Section 9 of the General Clauses Act, 1897. The limitation period commenced from 06.02.2020, making the order dated 05.02.2025 timely. Procedural compliance was affirmed as notices were properly served and opportunities to respond were granted. No interference was warranted with the order. However, acknowledging the petitioner's potential liability under Section 93, the court granted leave to file a statutory appeal under Section 107 within 30 days of receipt of the order. The appeal was accordingly dismissed.
The HC upheld the impugned order confirming tax liability on the deceased individual, rejecting the limitation plea under Section 74(10) of the GST Act by applying Section 9 of the General Clauses Act, 1897. The limitation period commenced from 06.02.2020, making the order dated 05.02.2025 timely. Procedural compliance was affirmed as notices were properly served and opportunities to respond were granted. No interference was warranted with the order. However, acknowledging the petitioner's potential liability under Section 93, the court granted leave to file a statutory appeal under Section 107 within 30 days of receipt of the order. The appeal was accordingly dismissed.
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