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...
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Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
The HC set aside the re-imposition of previously dropped demands relating to sub-contracting services and mobilisation advances, holding that those demands had been abandoned in earlier orders and were not before the appellate tribunal on remand; consequently they could not be resurrected without fresh adjudication or express direction. The court found a prima facie entitlement for the Petitioner to challenge only the matters remitted to the CESTAT and therefore permitted the Petitioner to pursue its appellate remedy before CESTAT subject to the conditions imposed by the HC. The petition is disposed, with adjudication on liability to be determined by CESTAT in accordance with the court's observations.
The HC set aside the re-imposition of previously dropped demands relating to sub-contracting services and mobilisation advances, holding that those demands had been abandoned in earlier orders and were not before the appellate tribunal on remand; consequently they could not be resurrected without fresh adjudication or express direction. The court found a prima facie entitlement for the Petitioner to challenge only the matters remitted to the CESTAT and therefore permitted the Petitioner to pursue its appellate remedy before CESTAT subject to the conditions imposed by the HC. The petition is disposed, with adjudication on liability to be determined by CESTAT in accordance with the court's observations.
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