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 quashed two provisional attachment orders issued under s.83 CGST against the petitioner for lack of a reasoned opinion and absence of proceedings under s.74, holding the attachment notices arbitrary and without legal basis. The court directed immediate release of the attached bank accounts within 48 hours. As to the blocked electronic credit ledger, the HC ordered the revenue to consider the petitioner's reply, afford a personal hearing and pass a reasoned order in accordance with law within two weeks. The writ petition was disposed of on these terms.
The HC quashed two provisional attachment orders issued under s.83 CGST against the petitioner for lack of a reasoned opinion and absence of proceedings under s.74, holding the attachment notices arbitrary and without legal basis. The court directed immediate release of the attached bank accounts within 48 hours. As to the blocked electronic credit ledger, the HC ordered the revenue to consider the petitioner's reply, afford a personal hearing and pass a reasoned order in accordance with law within two weeks. The writ petition was disposed of on these terms.
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