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 challenging issuance of Form GST DRC-01 dated 30.05.2025, holding that the petitioner's challenge was premature as no reply had been filed to the earlier Form GST DRC-01A dated 11.04.2025 issued under s.74(5) of the TNGST Act, 2017. The court found the petitioner's demand objection unsustainable in absence of a reply and declined substantive interference. Liberty was granted to the petitioner to file a reply/objection to the DRC-01 within two weeks of receipt of the order; on receipt, the respondent must consider it, issue a clear 14-day notice fixing a personal hearing, and thereafter pass orders on merits expeditiously and in accordance with law.
The HC dismissed the writ petition challenging issuance of Form GST DRC-01 dated 30.05.2025, holding that the petitioner's challenge was premature as no reply had been filed to the earlier Form GST DRC-01A dated 11.04.2025 issued under s.74(5) of the TNGST Act, 2017. The court found the petitioner's demand objection unsustainable in absence of a reply and declined substantive interference. Liberty was granted to the petitioner to file a reply/objection to the DRC-01 within two weeks of receipt of the order; on receipt, the respondent must consider it, issue a clear 14-day notice fixing a personal hearing, and thereafter pass orders on merits expeditiously and in accordance with law.
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