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 declined to entertain the writ, finding matters of alleged fraudulent availment of input tax credit ordinarily unsuitable for writ jurisdiction where complex factual and evidentiary inquiries and the protection of the public exchequer require exhaustion of statutory remedies. The Court held the Petitioner had received notices and filed responses, raised no substantive merits other than non-supply of RUDs, and was relegated to the statutory appellate route under s.107, CGST. The Petitioner is directed to file the appeal with the requisite pre-deposit by 30 November 2025; if so filed, the appeal will be admitted and not dismissed as time-barred. Petition disposed.
The HC declined to entertain the writ, finding matters of alleged fraudulent availment of input tax credit ordinarily unsuitable for writ jurisdiction where complex factual and evidentiary inquiries and the protection of the public exchequer require exhaustion of statutory remedies. The Court held the Petitioner had received notices and filed responses, raised no substantive merits other than non-supply of RUDs, and was relegated to the statutory appellate route under s.107, CGST. The Petitioner is directed to file the appeal with the requisite pre-deposit by 30 November 2025; if so filed, the appeal will be admitted and not dismissed as time-barred. Petition disposed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4800
Join Channel
TaxTMI 
