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 granted relief to the Petitioner, directing the tax authority to comply with statutory obligations under the CGST Act regarding seizure, copying and return of electronic devices and documents. The court held that inspection, search and seizure powers rest with the revenue, but materials not relied upon must be returned within 30 days and copies of seized data must be furnished to the Petitioner unless a written record shows prejudice to investigation. Finding that data extraction and cloning had largely been completed, the HC ordered the proprietor of the Petitioner to appear in person before an Authorised Officer to receive copies of the entire dataset and documents. The petition was disposed of accordingly.
The HC granted relief to the Petitioner, directing the tax authority to comply with statutory obligations under the CGST Act regarding seizure, copying and return of electronic devices and documents. The court held that inspection, search and seizure powers rest with the revenue, but materials not relied upon must be returned within 30 days and copies of seized data must be furnished to the Petitioner unless a written record shows prejudice to investigation. Finding that data extraction and cloning had largely been completed, the HC ordered the proprietor of the Petitioner to appear in person before an Authorised Officer to receive copies of the entire dataset and documents. The petition was disposed of accordingly.
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