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 held that once a deemed stay under Section 107 of the GST Act operates, there is no statutory authority to continue provisional attachment or restraint of funds. The petitioner was directed to furnish an undertaking to the 3rd respondent to retain all amounts refunded and any future sale proceeds in the petitioner's bank account until disposal of the appeal, and to maintain a minimum balance of Rs.245 crores after adjusting Rs.24.4 crores treated as pre-deposit. The petitioner must also undertake to keep intact the refunded portion of Rs.170 crores recovered earlier until the appeal is finally disposed of. Petition disposed of.
HC held that once a deemed stay under Section 107 of the GST Act operates, there is no statutory authority to continue provisional attachment or restraint of funds. The petitioner was directed to furnish an undertaking to the 3rd respondent to retain all amounts refunded and any future sale proceeds in the petitioner's bank account until disposal of the appeal, and to maintain a minimum balance of Rs.245 crores after adjusting Rs.24.4 crores treated as pre-deposit. The petitioner must also undertake to keep intact the refunded portion of Rs.170 crores recovered earlier until the appeal is finally disposed of. Petition disposed of.
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