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...
Show cause notice sought cancellation of GST registration for alleged breach of Rule 21(e) by claiming input tax credit from non existent or non operating suppliers; the notice relied on a DGGI communication as supporting material. Petitioner filed specific replies (including Form GST REG 18) addressing the allegation, indicating understanding of charges; the court found no prejudice from the mode of communication and held the proper officer may decide the cancellation matter on the basis of those replies in accordance with law within two weeks. The writ petition was disposed with that direction and the petitioner's cited decisions were found inapplicable.
Show cause notice sought cancellation of GST registration for alleged breach of Rule 21(e) by claiming input tax credit from non existent or non operating suppliers; the notice relied on a DGGI communication as supporting material. Petitioner filed specific replies (including Form GST REG 18) addressing the allegation, indicating understanding of charges; the court found no prejudice from the mode of communication and held the proper officer may decide the cancellation matter on the basis of those replies in accordance with law within two weeks. The writ petition was disposed with that direction and the petitioner's cited decisions were found inapplicable.
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