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 High Court found the impugned order was passed by the State Tax Officer rather than the Commissioner and remitted the matter for fresh adjudication on merits; remand is conditional on the petitioner depositing 10% of the disputed tax (confirmed in the impugned order) in cash or from the Electronic Cash Ledger within 30 days and filing a substantive reply with documents, treating the impugned order as an addendum to the Show Cause Notice. Because the petitioner's bank account is attached, the respondent may debit 5% each towards CGST and TNGST from the petitioner's Electronic Cash Ledger; failure to comply permits statutory recovery as if the writ were dismissed.
The High Court found the impugned order was passed by the State Tax Officer rather than the Commissioner and remitted the matter for fresh adjudication on merits; remand is conditional on the petitioner depositing 10% of the disputed tax (confirmed in the impugned order) in cash or from the Electronic Cash Ledger within 30 days and filing a substantive reply with documents, treating the impugned order as an addendum to the Show Cause Notice. Because the petitioner's bank account is attached, the respondent may debit 5% each towards CGST and TNGST from the petitioner's Electronic Cash Ledger; failure to comply permits statutory recovery as if the writ were dismissed.
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