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...
At the investigation stage of GST detention proceedings, the Court found prima facie material supporting continued custody of the goods and conveyance, including interception of the vehicle en route to a destination different from the declared one and other investigative circumstances. The affixture of the detention order on the vehicle and office notice board, after non-appearance of the persons summoned, was not treated as illegal, and extension of time for inspection was considered a permissible statutory step. The petitioner's allegation that his statement was coerced was held to raise disputed factual questions unsuitable for Article 226 scrutiny. The writ petition was dismissed, subject to statutory remedies and a direction to furnish the detention order if the petitioner appears.
At the investigation stage of GST detention proceedings, the Court found prima facie material supporting continued custody of the goods and conveyance, including interception of the vehicle en route to a destination different from the declared one and other investigative circumstances. The affixture of the detention order on the vehicle and office notice board, after non-appearance of the persons summoned, was not treated as illegal, and extension of time for inspection was considered a permissible statutory step. The petitioner's allegation that his statement was coerced was held to raise disputed factual questions unsuitable for Article 226 scrutiny. The writ petition was dismissed, subject to statutory remedies and a direction to furnish the detention order if the petitioner appears.
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