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 quashed the impugned Recovery Notice dated 15.09.2025 issued by the 1st Respondent under s.79(1)(c)(i) of the respective GST enactments, holding that the alleged arrears had been largely discharged by the Petitioner through payments between 21.10.2023 and 11.03.2024 (and subsequently), leaving no subsisting liability as asserted in the notice; the Court noted earlier orders quantifying liabilities and a small additional interest demand for a prior period. The 1st Respondent was granted liberty to issue a fresh recovery notice under s.79(1)(c)(i) if bona fide other arrears remain outstanding. Petition stands disposed of.
The HC quashed the impugned Recovery Notice dated 15.09.2025 issued by the 1st Respondent under s.79(1)(c)(i) of the respective GST enactments, holding that the alleged arrears had been largely discharged by the Petitioner through payments between 21.10.2023 and 11.03.2024 (and subsequently), leaving no subsisting liability as asserted in the notice; the Court noted earlier orders quantifying liabilities and a small additional interest demand for a prior period. The 1st Respondent was granted liberty to issue a fresh recovery notice under s.79(1)(c)(i) if bona fide other arrears remain outstanding. Petition stands disposed of.
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