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 remitted the matter to the Commissioner, CGST, Ghaziabad, directing reconsideration of the Electronic Credit Ledger blockage effected under Rule 86A, CGST Rules, 2017, on grounds implicating principles of natural justice and the requirement of a pre-decisional hearing. The petitioner is ordered to file a reply/objection within one week from the judgment. A personal hearing is fixed for 25 August 2025 at 11:00 AM before the Commissioner. The Commissioner is directed to pass a reasoned, expeditious order preferably within one week of the hearing. The petition is disposed of, without adjudicating the framed legal questions, for fresh decision in accordance with law.
The HC remitted the matter to the Commissioner, CGST, Ghaziabad, directing reconsideration of the Electronic Credit Ledger blockage effected under Rule 86A, CGST Rules, 2017, on grounds implicating principles of natural justice and the requirement of a pre-decisional hearing. The petitioner is ordered to file a reply/objection within one week from the judgment. A personal hearing is fixed for 25 August 2025 at 11:00 AM before the Commissioner. The Commissioner is directed to pass a reasoned, expeditious order preferably within one week of the hearing. The petition is disposed of, without adjudicating the framed legal questions, for fresh decision in accordance with law.
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