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 set aside the impugned penalty orders and their common summary in Form GST DRC-07 (dated 06.06.2025) on grounds of procedural infirmity-absence of the assessing officer's digital signature and omission of a DIN-finding such defects render the orders invalid and breach principles of natural justice. The writ petition was disposed of, with the Court granting the Respondent liberty to initiate fresh assessment proceedings, subject to issuance of proper notice and execution of the resultant orders bearing an assigned signature and DIN. No costs were awarded.
The HC set aside the impugned penalty orders and their common summary in Form GST DRC-07 (dated 06.06.2025) on grounds of procedural infirmity-absence of the assessing officer's digital signature and omission of a DIN-finding such defects render the orders invalid and breach principles of natural justice. The writ petition was disposed of, with the Court granting the Respondent liberty to initiate fresh assessment proceedings, subject to issuance of proper notice and execution of the resultant orders bearing an assigned signature and DIN. No costs were awarded.
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