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 disposed of the writ petition challenging a bank attachment notice issued under the GST enactments and directed the Respondents to treat the impugned notice as a notice to show cause why penalty, tax and interest should not be recovered from the Petitioner. The Petitioner was permitted to file a detailed representation within 30 days of receipt of the order. The 1st Respondent or any authorized officer was directed to adjudicate the representation and pass a reasoned order on merits and in accordance with law within two months thereafter. The petition is disposed of accordingly.
The HC disposed of the writ petition challenging a bank attachment notice issued under the GST enactments and directed the Respondents to treat the impugned notice as a notice to show cause why penalty, tax and interest should not be recovered from the Petitioner. The Petitioner was permitted to file a detailed representation within 30 days of receipt of the order. The 1st Respondent or any authorized officer was directed to adjudicate the representation and pass a reasoned order on merits and in accordance with law within two months thereafter. The petition is disposed of accordingly.
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