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 adjudged that the Petitioner procured Input Tax Credit from fraudulent suppliers and deliberately misrepresented the nature and status of his business to mislead the Court and evade departmental proceedings. The HC upheld cancellation of the Petitioner's GST registration effective 30 June 2025, found the petition unsustainable, and dismissed the petition. The Court imposed punitive costs of Rs. 5,00,000 on the Petitioner and observed that more severe proceedings could be initiated; however, further departmental action already initiated will proceed and the Court refrained from taking additional punitive measures pending those processes. The HC's order thus resolves the dispute against the Petitioner and preserves administrative remedies.
The HC adjudged that the Petitioner procured Input Tax Credit from fraudulent suppliers and deliberately misrepresented the nature and status of his business to mislead the Court and evade departmental proceedings. The HC upheld cancellation of the Petitioner's GST registration effective 30 June 2025, found the petition unsustainable, and dismissed the petition. The Court imposed punitive costs of Rs. 5,00,000 on the Petitioner and observed that more severe proceedings could be initiated; however, further departmental action already initiated will proceed and the Court refrained from taking additional punitive measures pending those processes. The HC's order thus resolves the dispute against the Petitioner and preserves administrative remedies.
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