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...
An apparent clerical error in the summary assessment could not be carried forward to reject a Section 128A GST amnesty waiver application. The original order showed that the demand comprised tax, interest and penalty, with penalty being only a part of the total demand, so the authority was required to examine the waiver request on the correct basis and on its own merits. The High Court set aside the rejection order and remanded the matter for fresh consideration after treating the demand as consisting of tax, interest and penalty and after hearing the petitioner.
An apparent clerical error in the summary assessment could not be carried forward to reject a Section 128A GST amnesty waiver application. The original order showed that the demand comprised tax, interest and penalty, with penalty being only a part of the total demand, so the authority was required to examine the waiver request on the correct basis and on its own merits. The High Court set aside the rejection order and remanded the matter for fresh consideration after treating the demand as consisting of tax, interest and penalty and after hearing the petitioner.
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