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 impugned composite show-cause notices and assessment orders for consolidating multiple tax periods, holding that a single SCN or composite assessment cannot cover more than one tax period (monthly or annual as applicable) and that separate assessments must be framed for each assessment year; divergence in High Courts' precedents noted but statutory interpretation, read with related provisions and the rights to benefits and appeals under the GST framework, requires distinct orders per period. The writ petitions were disposed of, quashing the composite orders and permitting respondents to initiate fresh proceedings confined to each assessment year separately.
The HC set aside impugned composite show-cause notices and assessment orders for consolidating multiple tax periods, holding that a single SCN or composite assessment cannot cover more than one tax period (monthly or annual as applicable) and that separate assessments must be framed for each assessment year; divergence in High Courts' precedents noted but statutory interpretation, read with related provisions and the rights to benefits and appeals under the GST framework, requires distinct orders per period. The writ petitions were disposed of, quashing the composite orders and permitting respondents to initiate fresh proceedings confined to each assessment year separately.
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