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 petition and upheld the impugned order, finding that the petitioner failed to produce requisite documentation evidencing movement of two HR coils from the branch to the job-worker premises. The court held that, under Rules 45 and 55 of the GST Rules, a delivery challan in the prescribed format must accompany goods sent for job-work, and no e-way bill was produced at any stage. In the absence of a delivery challan and e-way bill, the goods could not be considered accompanied by required documents, rendering the investigative and enforcement proceedings lawful and non-arbitrary. No interference with the impugned order was warranted.
The HC dismissed the petition and upheld the impugned order, finding that the petitioner failed to produce requisite documentation evidencing movement of two HR coils from the branch to the job-worker premises. The court held that, under Rules 45 and 55 of the GST Rules, a delivery challan in the prescribed format must accompany goods sent for job-work, and no e-way bill was produced at any stage. In the absence of a delivery challan and e-way bill, the goods could not be considered accompanied by required documents, rendering the investigative and enforcement proceedings lawful and non-arbitrary. No interference with the impugned order was warranted.
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