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 quashed the seizure and ancillary orders and allowed the writ petition, holding that the interstate movement of the crane for execution of a works contract did not constitute a supply of goods or services and thus attracted no IGST. The court held Board circulars to be binding on authorities and, in absence of intent to evade tax, Section 24 principles did not permit seizure. Consequently the impugned seizure was invalid and the authorities are directed to release the goods forthwith upon production of a certified copy of the order. Costs not addressed.
HC quashed the seizure and ancillary orders and allowed the writ petition, holding that the interstate movement of the crane for execution of a works contract did not constitute a supply of goods or services and thus attracted no IGST. The court held Board circulars to be binding on authorities and, in absence of intent to evade tax, Section 24 principles did not permit seizure. Consequently the impugned seizure was invalid and the authorities are directed to release the goods forthwith upon production of a certified copy of the order. Costs not addressed.
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