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...
Assessee's duty to monitor the GST web portal and consequent estoppel: after participation in proceedings and failure to produce documents or attend hearings, the petitioner could not credibly claim ignorance of an uploaded assessment order, and delay of eleven months constituted laches leading to dismissal of the writ as meritless. Effect: cancellation of GST registration after quantification does not negate notice or knowledge of assessment. Conditional relief and procedural accommodation: court granted liberty to file appeal subject to payment of an additional 10% over the statutory pre-deposit (total 20%) and directed partial bank release to meet that pre-deposit, with the appellate authority to admit and decide the appeal on merits.
Assessee's duty to monitor the GST web portal and consequent estoppel: after participation in proceedings and failure to produce documents or attend hearings, the petitioner could not credibly claim ignorance of an uploaded assessment order, and delay of eleven months constituted laches leading to dismissal of the writ as meritless. Effect: cancellation of GST registration after quantification does not negate notice or knowledge of assessment. Conditional relief and procedural accommodation: court granted liberty to file appeal subject to payment of an additional 10% over the statutory pre-deposit (total 20%) and directed partial bank release to meet that pre-deposit, with the appellate authority to admit and decide the appeal on merits.
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