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 held that the provisional attachment of the bank account was unsustainable following the filing of an appeal accompanied by the requisite pre-deposit under Section 107(7) of the CGST Act, 2017. The Court affirmed that the filing of the appeal with the pre-deposit automatically operates as a stay on the impugned order, thereby rendering the attachment ineffective. Consequently, the petition challenging the attachment was disposed of in favor of the appellant.
The HC held that the provisional attachment of the bank account was unsustainable following the filing of an appeal accompanied by the requisite pre-deposit under Section 107(7) of the CGST Act, 2017. The Court affirmed that the filing of the appeal with the pre-deposit automatically operates as a stay on the impugned order, thereby rendering the attachment ineffective. Consequently, the petition challenging the attachment was disposed of in favor of the appellant.
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