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 dismissed the writ petitions, holding that the petitioner's failure to submit the latest GSTR-3B within the prescribed period constituted a material deviation rendering the bid non-responsive. The Court found no cogent explanation for the delayed filing, concluded the omission substantially affected bid validity and was inconsistent with tender conditions, and declined to exercise judicial review in the absence of demonstrable mala fides or overriding public interest. The technical committee's declaration of non-responsiveness was upheld as neither perverse nor arbitrary, and the petitioners' challenge to the procurement process was rejected for lacking merit.
The HC dismissed the writ petitions, holding that the petitioner's failure to submit the latest GSTR-3B within the prescribed period constituted a material deviation rendering the bid non-responsive. The Court found no cogent explanation for the delayed filing, concluded the omission substantially affected bid validity and was inconsistent with tender conditions, and declined to exercise judicial review in the absence of demonstrable mala fides or overriding public interest. The technical committee's declaration of non-responsiveness was upheld as neither perverse nor arbitrary, and the petitioners' challenge to the procurement process was rejected for lacking merit.
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