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 refused interim relief under Section 74 of the W.B.G.S.T./C.G.S.T. Act, 2017, noting alleged suppression of facts to evade tax. The court declined interim protection and directed that Rs. 5,50,62,464, which the appellants/petitioners assert was paid under compulsion but which the Revenue disputes, shall be treated as a deposit and shall abide by the final adjudicatory orders in the writ petition. Observing that over 50% of the tax demand has already been recovered, the court held the Revenue's interest is adequately protected and that the payment exceeds the 10% deposit ordinarily required on appeal, reinforcing treatment as a deposit. The writ petition is listed before the appropriate Bench on 28 November 2025.
HC refused interim relief under Section 74 of the W.B.G.S.T./C.G.S.T. Act, 2017, noting alleged suppression of facts to evade tax. The court declined interim protection and directed that Rs. 5,50,62,464, which the appellants/petitioners assert was paid under compulsion but which the Revenue disputes, shall be treated as a deposit and shall abide by the final adjudicatory orders in the writ petition. Observing that over 50% of the tax demand has already been recovered, the court held the Revenue's interest is adequately protected and that the payment exceeds the 10% deposit ordinarily required on appeal, reinforcing treatment as a deposit. The writ petition is listed before the appropriate Bench on 28 November 2025.
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