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...
Ratification of resignation acceptance validates separation retrospectively, while withdrawal may be refused through reasoned administrative discretio...
A writ challenge to a notice initiating revision under Section 108 was held premature because no final revisional order had yet been passed. The High Court left open the petitioner's objections on jurisdiction and maintainability to be raised before the revisional authority and declined interference at the threshold. At the same time, it protected the petitioner by directing conditional release of the goods pending revision, subject to an additional deposit, filing of an affidavit undertaking to abide by the revisional order, and participation in the revisional proceedings. The writ petition was disposed of without examining the merits of the revision challenge.
A writ challenge to a notice initiating revision under Section 108 was held premature because no final revisional order had yet been passed. The High Court left open the petitioner's objections on jurisdiction and maintainability to be raised before the revisional authority and declined interference at the threshold. At the same time, it protected the petitioner by directing conditional release of the goods pending revision, subject to an additional deposit, filing of an affidavit undertaking to abide by the revisional order, and participation in the revisional proceedings. The writ petition was disposed of without examining the merits of the revision challenge.
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