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 dismissed the writ petition as not maintainable insofar as an alternative statutory remedy exists and the impugned order is appealable under Section 107. The court noted material suggesting the petitioner's GST registration was recent and that the entity may have been constituted to fraudulently avail ineligible input tax credit via fake, non-existent suppliers; business operations ceased following the petitioner's arrest. The petitioner's reply to the show-cause notice was found unpersuasive. Although the petition was filed within the limitation period, the period for appeal has lapsed; accordingly the HC permitted the petitioner to institute the statutory appeal by 15 December 2025 subject to depositing the requisite pre-deposit, and disposed of the petition.
HC dismissed the writ petition as not maintainable insofar as an alternative statutory remedy exists and the impugned order is appealable under Section 107. The court noted material suggesting the petitioner's GST registration was recent and that the entity may have been constituted to fraudulently avail ineligible input tax credit via fake, non-existent suppliers; business operations ceased following the petitioner's arrest. The petitioner's reply to the show-cause notice was found unpersuasive. Although the petition was filed within the limitation period, the period for appeal has lapsed; accordingly the HC permitted the petitioner to institute the statutory appeal by 15 December 2025 subject to depositing the requisite pre-deposit, and disposed of the petition.
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