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...
HC dismisses the petition filed by the petitioner summarily for delay, holding that no substantive relief remains as explicit guidelines govern recovery of outstanding dues where first appeal has been disposed of until the Appellate Tribunal becomes operational. The Court reserves liberty for the petitioner to comply with Circular No. 224/18/2024-GST by filing an undertaking with the jurisdictional officer to institute an appeal before the Appellate Tribunal when it becomes operational within the time prescribed under Section 112 of the CGST Act and to remit the prescribed pre-deposit under Section 112(8) within 30 days of receipt of this order. Upon filing such undertaking, recovery of the remaining amount shall be stayed pursuant to Section 112(9). Petition disposed.
HC dismisses the petition filed by the petitioner summarily for delay, holding that no substantive relief remains as explicit guidelines govern recovery of outstanding dues where first appeal has been disposed of until the Appellate Tribunal becomes operational. The Court reserves liberty for the petitioner to comply with Circular No. 224/18/2024-GST by filing an undertaking with the jurisdictional officer to institute an appeal before the Appellate Tribunal when it becomes operational within the time prescribed under Section 112 of the CGST Act and to remit the prescribed pre-deposit under Section 112(8) within 30 days of receipt of this order. Upon filing such undertaking, recovery of the remaining amount shall be stayed pursuant to Section 112(9). Petition disposed.
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