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 held the demand confirmed where the petitioner failed to reply to the Notice in Form GST DRC-01 and rejected the rectification application under Section 161 as time-barred and meritless, finding no procedural infirmity in the assessment order. The writ petition was dismissed as filed long after the statutory period for appeal had lapsed. The HC granted limited relief by permitting the petitioner liberty to file the statutory appellate remedy within 30 days from receipt of the order, subject to deposit of 50% of the disputed tax in cash; upon compliance the Deputy Commissioner (GST Appeals) shall entertain and dispose of the appeal notwithstanding limitation. Petition disposed.
HC held the demand confirmed where the petitioner failed to reply to the Notice in Form GST DRC-01 and rejected the rectification application under Section 161 as time-barred and meritless, finding no procedural infirmity in the assessment order. The writ petition was dismissed as filed long after the statutory period for appeal had lapsed. The HC granted limited relief by permitting the petitioner liberty to file the statutory appellate remedy within 30 days from receipt of the order, subject to deposit of 50% of the disputed tax in cash; upon compliance the Deputy Commissioner (GST Appeals) shall entertain and dispose of the appeal notwithstanding limitation. Petition disposed.
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