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 declined to adjudicate substantive challenges to the legislative competence and validity of Sections 69 and 70, observing that the SC has already resolved those issues in a controlling decision addressing CGST officers' powers to summon, seize and obtain production of documents and to arrest persons suspected of tax evasion, and prescribing statutory safeguards in relation to arrest under Section 132. As the petitions' core contention is foreclosed by the SC precedent and the remaining reliefs were not pressed, the writ petitions were dismissed and disposed of. The court's order leaves intact the operative statutory powers and the SC-prescribed arrest safeguards under the CGST framework.
The HC declined to adjudicate substantive challenges to the legislative competence and validity of Sections 69 and 70, observing that the SC has already resolved those issues in a controlling decision addressing CGST officers' powers to summon, seize and obtain production of documents and to arrest persons suspected of tax evasion, and prescribing statutory safeguards in relation to arrest under Section 132. As the petitions' core contention is foreclosed by the SC precedent and the remaining reliefs were not pressed, the writ petitions were dismissed and disposed of. The court's order leaves intact the operative statutory powers and the SC-prescribed arrest safeguards under the CGST framework.
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