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...
Validity of service by uploading a show-cause notice on the common GST portal after cancellation of registration was treated as deficient; the prevailing principle requires alternative modes of service where registration is cancelled, following prior authority. The impugned adjudication order issued after portal-only service was quashed, with liberty to the revenue to issue a fresh notice and re-adjudicate. The petitioner must be afforded an opportunity for personal hearing in accordance with the statutory right to be heard (audi alteram partem) during re-adjudication.
Validity of service by uploading a show-cause notice on the common GST portal after cancellation of registration was treated as deficient; the prevailing principle requires alternative modes of service where registration is cancelled, following prior authority. The impugned adjudication order issued after portal-only service was quashed, with liberty to the revenue to issue a fresh notice and re-adjudicate. The petitioner must be afforded an opportunity for personal hearing in accordance with the statutory right to be heard (audi alteram partem) during re-adjudication.
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