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 examined challenge to an appellate order setting aside a refund sanction relating to alleged zero-rated export of services under the IGST Act, 2017. HC held that the appellate authority had acted in violation of principles of natural justice, having failed to apply its mind or record adequate reasons, particularly regarding classification of services as exports and the applicability of s.13(3)-(13) IGST Act. Concluding that the impugned order was vitiated by non-application of mind, HC set it aside. The matter was remanded to the appellate authority for de novo consideration, with a direction to pass a reasoned order after granting due notice and hearing to the petitioner, who shall appear on 27.10.2025.
HC examined challenge to an appellate order setting aside a refund sanction relating to alleged zero-rated export of services under the IGST Act, 2017. HC held that the appellate authority had acted in violation of principles of natural justice, having failed to apply its mind or record adequate reasons, particularly regarding classification of services as exports and the applicability of s.13(3)-(13) IGST Act. Concluding that the impugned order was vitiated by non-application of mind, HC set it aside. The matter was remanded to the appellate authority for de novo consideration, with a direction to pass a reasoned order after granting due notice and hearing to the petitioner, who shall appear on 27.10.2025.
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