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 disposed the writ petition and remitted the matter to the Respondent for a de novo adjudication, holding the appeal was filed beyond the condonable limitation and the Applicant failed to file a reply. Conditioned on the Applicant depositing 40% of the disputed tax in cash through the Electronic Cash Register within 30 days of service of this order and filing a consolidated reply to the show-cause notice in GST DRC-01 dated 14.08.2023 treating the impugned order of 30.12.2023 as an addendum within the same 30-day period, the Respondent is directed to pass a final order on merits and in accordance with law expeditiously, preferably within three months.
HC disposed the writ petition and remitted the matter to the Respondent for a de novo adjudication, holding the appeal was filed beyond the condonable limitation and the Applicant failed to file a reply. Conditioned on the Applicant depositing 40% of the disputed tax in cash through the Electronic Cash Register within 30 days of service of this order and filing a consolidated reply to the show-cause notice in GST DRC-01 dated 14.08.2023 treating the impugned order of 30.12.2023 as an addendum within the same 30-day period, the Respondent is directed to pass a final order on merits and in accordance with law expeditiously, preferably within three months.
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