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 petition and upheld that issuance of a consolidated show cause notice for multiple years is permissible where the primary allegation is fraudulent availment of input tax credit. The court recognized that the impugned order is appealable under Section 107, CGST Act, 2017, and disposed of the petition while granting the Petitioner liberty to file an appeal by 30 September 2025 subject to requisite pre-deposit(s). If the appeal is instituted within the stipulated period, the Appellate Authority is directed not to reject it on limitation grounds but to adjudicate the challenge on its merits. The petition is disposed.
HC dismissed the petition and upheld that issuance of a consolidated show cause notice for multiple years is permissible where the primary allegation is fraudulent availment of input tax credit. The court recognized that the impugned order is appealable under Section 107, CGST Act, 2017, and disposed of the petition while granting the Petitioner liberty to file an appeal by 30 September 2025 subject to requisite pre-deposit(s). If the appeal is instituted within the stipulated period, the Appellate Authority is directed not to reject it on limitation grounds but to adjudicate the challenge on its merits. The petition is disposed.
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