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HC dismissed as withdrawn a writ challenging an order passed by the proper officer under s.73(9) of the WBGST/CGST Act, 2017, where the departmental appellate tribunal had not been constituted. The Court noted that, at the time of filing, a departmental circular dated 11 July 2024 was already extant and the petitioners had delayed payment of the amount determined by tax authorities. The petitioners sought withdrawal of the writ; the HC declined to permit invocation of extraordinary jurisdiction to further delay the statutory revenue deposit and ordered dismissal of the petition as withdrawn, subject to payment of costs of Rs.100,000 to the GST authorities.
HC dismissed as withdrawn a writ challenging an order passed by the proper officer under s.73(9) of the WBGST/CGST Act, 2017, where the departmental appellate tribunal had not been constituted. The Court noted that, at the time of filing, a departmental circular dated 11 July 2024 was already extant and the petitioners had delayed payment of the amount determined by tax authorities. The petitioners sought withdrawal of the writ; the HC declined to permit invocation of extraordinary jurisdiction to further delay the statutory revenue deposit and ordered dismissal of the petition as withdrawn, subject to payment of costs of Rs.100,000 to the GST authorities.
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