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 held Section 171 CGST Act, 2017 and the specified Rules raise substantive issues warranting re-examination and remanded the matter for fact-finding by the Principal Bench of the GSTAT as NAPA. Noting a cut-off of 01.04.2025 for acceptance of anti-profiteering requests, the Court found that, given the GST rate increase affecting the Petitioner, the Directorate General's investigation required scrutiny to determine whether findings of profiteering rested on evidence or mere conjecture. The impugned order dated 29.08.2022 was set aside and the petition was disposed of by remand for fresh hearing before the Principal Bench of GSTAT on 14.10.2025.
The HC held Section 171 CGST Act, 2017 and the specified Rules raise substantive issues warranting re-examination and remanded the matter for fact-finding by the Principal Bench of the GSTAT as NAPA. Noting a cut-off of 01.04.2025 for acceptance of anti-profiteering requests, the Court found that, given the GST rate increase affecting the Petitioner, the Directorate General's investigation required scrutiny to determine whether findings of profiteering rested on evidence or mere conjecture. The impugned order dated 29.08.2022 was set aside and the petition was disposed of by remand for fresh hearing before the Principal Bench of GSTAT on 14.10.2025.
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