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...
On certiorari review of an order under Section 74 concerning alleged wrongful availment of input tax credit by misstatement and suppression, the court found that reasons were recorded and relevant factors considered and therefore declined to interfere absent any shown perversity or mala fides; the petitioner's request to waive or reduce the statutory pre deposit for filing a statutory appeal was refused for lack of extraordinary circumstances; the writ petition challenging the Section 74 order was dismissed, and the court's observations were treated as tentative and without prejudice to any appeal on merits.
On certiorari review of an order under Section 74 concerning alleged wrongful availment of input tax credit by misstatement and suppression, the court found that reasons were recorded and relevant factors considered and therefore declined to interfere absent any shown perversity or mala fides; the petitioner's request to waive or reduce the statutory pre deposit for filing a statutory appeal was refused for lack of extraordinary circumstances; the writ petition challenging the Section 74 order was dismissed, and the court's observations were treated as tentative and without prejudice to any appeal on merits.
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