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...
GST Common Portal functionality was addressed to allow a registered taxpayer to opt out of the QRMP Scheme and shift to regular monthly filing of GSTR-1 and GSTR-3B. The Court accepted that the migration could be implemented through backend changes on the portal and directed GSTN and the GST authorities to make the necessary changes. The petitioner was required to file the returns with applicable late fees and interest, while retaining liberty to seek refund before the concerned Commissionerate in accordance with law. The migration was permitted with effect from March 2026.
GST Common Portal functionality was addressed to allow a registered taxpayer to opt out of the QRMP Scheme and shift to regular monthly filing of GSTR-1 and GSTR-3B. The Court accepted that the migration could be implemented through backend changes on the portal and directed GSTN and the GST authorities to make the necessary changes. The petitioner was required to file the returns with applicable late fees and interest, while retaining liberty to seek refund before the concerned Commissionerate in accordance with law. The migration was permitted with effect from March 2026.
Note: It is a system-generated summary and is for quick reference only.