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 dismissed the challenge insofar as it sought to impugn the authenticity of the SCN and order on the ground of absence of physical signatures, holding that GST-portal uploads authenticated by the concerned officer's digital key and bearing officer name/designation are valid unless misuse of the digital key is shown. The petition alleging defects including non-issuance of a pre-consultation notice under r.142(1A) and disputes over excess ITC (including claims from cancelled dealers, return-defaulters and non-business/exempt supplies and reconciliation issues) was disposed of with the direction that the petitioner may pursue an appeal under s.107 CGST by 30 November 2025, which shall not be dismissed on limitation and shall be decided on merits.
The HC dismissed the challenge insofar as it sought to impugn the authenticity of the SCN and order on the ground of absence of physical signatures, holding that GST-portal uploads authenticated by the concerned officer's digital key and bearing officer name/designation are valid unless misuse of the digital key is shown. The petition alleging defects including non-issuance of a pre-consultation notice under r.142(1A) and disputes over excess ITC (including claims from cancelled dealers, return-defaulters and non-business/exempt supplies and reconciliation issues) was disposed of with the direction that the petitioner may pursue an appeal under s.107 CGST by 30 November 2025, which shall not be dismissed on limitation and shall be decided on merits.
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