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 disposed the writ petition, directing the petitioner to appear before the Additional Assistant Director, DGGI, Bhopal Zonal Unit on 17.09.2025 at 14:30 with all documents relating to the summons/notice purportedly issued under Section 74 of the CGST Act. The AD shall verify the documents and, applying the SC's interpretation of Section 6(2)(b) of the CGST Act - namely that "initiation of any proceedings" denotes formal adjudicatory commencement by issuance of a show-cause notice (and does not include issuance of summons or searches/seizures), and that "subject matter" denotes the specific tax liability or obligation sought to be assessed or recovered - decide whether to proceed further. Petition stands disposed.
The HC disposed the writ petition, directing the petitioner to appear before the Additional Assistant Director, DGGI, Bhopal Zonal Unit on 17.09.2025 at 14:30 with all documents relating to the summons/notice purportedly issued under Section 74 of the CGST Act. The AD shall verify the documents and, applying the SC's interpretation of Section 6(2)(b) of the CGST Act - namely that "initiation of any proceedings" denotes formal adjudicatory commencement by issuance of a show-cause notice (and does not include issuance of summons or searches/seizures), and that "subject matter" denotes the specific tax liability or obligation sought to be assessed or recovered - decide whether to proceed further. Petition stands disposed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4798
Join Channel
TaxTMI 
