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...
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Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
HC held that the invoice produced in favour of the petitioner and corroborative documentary evidence (wedding card) sufficiently established the legitimacy of the seized goods; the State/Department failed to impugn the invoice or the marriage fact. The December 31, 2018 Circular was held applicable; the detention and seizure could not be sustained. The impugned order dated July 9, 2025 was quashed and set aside. Authorities are directed to undertake the statutory exercise under Section 129(1)(a) of the Uttar Pradesh Goods and Services Tax Act, 2017 within three weeks and to release the goods to the petitioner upon payment of the penalty prescribed under that provision. Petition disposed of.
HC held that the invoice produced in favour of the petitioner and corroborative documentary evidence (wedding card) sufficiently established the legitimacy of the seized goods; the State/Department failed to impugn the invoice or the marriage fact. The December 31, 2018 Circular was held applicable; the detention and seizure could not be sustained. The impugned order dated July 9, 2025 was quashed and set aside. Authorities are directed to undertake the statutory exercise under Section 129(1)(a) of the Uttar Pradesh Goods and Services Tax Act, 2017 within three weeks and to release the goods to the petitioner upon payment of the penalty prescribed under that provision. Petition disposed of.
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