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 dismissed the writ petition under Articles 226 and 227 for want of maintainability, holding that the petitioner failed to demonstrate sufficient cause for inordinate delay and unjustifiably bypassed the statutory alternative remedy to challenge the impugned order dated 17 August 2024. Allegations concerning excess input tax credit in GSTR-3B vis-Ã -vis GSTR-2A did not justify invocation of discretionary writ jurisdiction absent promptness or exceptional circumstances. Applying established parameters restricting exercise of Article 226 discretion, the Court declined to exercise relief against an assessment/order capable of statutory challenge and accordingly dismissed the petition.
The HC dismissed the writ petition under Articles 226 and 227 for want of maintainability, holding that the petitioner failed to demonstrate sufficient cause for inordinate delay and unjustifiably bypassed the statutory alternative remedy to challenge the impugned order dated 17 August 2024. Allegations concerning excess input tax credit in GSTR-3B vis-Ã -vis GSTR-2A did not justify invocation of discretionary writ jurisdiction absent promptness or exceptional circumstances. Applying established parameters restricting exercise of Article 226 discretion, the Court declined to exercise relief against an assessment/order capable of statutory challenge and accordingly dismissed the petition.
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