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 allowed the writ petition, holding that the impugned composite assessment order in Form GST DRC-07 dated 09.01.2025 and the corresponding summaries dated 17.01.2025 issued against the petitioner are set aside and the matters remanded to the 1st respondent for fresh adjudication after affording due opportunity of hearing. The Court clarified that electronically issued show-cause notices and summaries require digital authentication but, where an RFN indicates affixation of a digital signature, challenge on absence of physical/digital signature is negated. Further, issuing a common SCN or common order for multiple assessment periods is impermissible; separate SCNs, orders and summaries must be issued for each tax period.
The HC allowed the writ petition, holding that the impugned composite assessment order in Form GST DRC-07 dated 09.01.2025 and the corresponding summaries dated 17.01.2025 issued against the petitioner are set aside and the matters remanded to the 1st respondent for fresh adjudication after affording due opportunity of hearing. The Court clarified that electronically issued show-cause notices and summaries require digital authentication but, where an RFN indicates affixation of a digital signature, challenge on absence of physical/digital signature is negated. Further, issuing a common SCN or common order for multiple assessment periods is impermissible; separate SCNs, orders and summaries must be issued for each tax period.
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