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 allowed the petition, holding that principles of natural justice were violated by uploading the show-cause notice on the GST portal without physically serving the Petitioner and without affording a hearing. The Court found the petitioner's explanation for a 288-day delay in filing the appeal to be bona fide and, accordingly, set aside the impugned order dated 28.03.2025 passed by Respondent 1 and condoned the 288-day delay. Conditionally permitting the appeal to proceed, the HC directed the Petitioner to remit an additional deposit of 5% of the disputed tax demand, over and above the 10% statutory deposit (as agreed), to Respondent 2 within four weeks of receipt of the order. Petition disposed.
The HC allowed the petition, holding that principles of natural justice were violated by uploading the show-cause notice on the GST portal without physically serving the Petitioner and without affording a hearing. The Court found the petitioner's explanation for a 288-day delay in filing the appeal to be bona fide and, accordingly, set aside the impugned order dated 28.03.2025 passed by Respondent 1 and condoned the 288-day delay. Conditionally permitting the appeal to proceed, the HC directed the Petitioner to remit an additional deposit of 5% of the disputed tax demand, over and above the 10% statutory deposit (as agreed), to Respondent 2 within four weeks of receipt of the order. Petition disposed.
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