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...
Overlapping GST proceedings were not examined on merits in writ jurisdiction because the petitioner had not participated in the second proceedings to place the alleged overlap before the proper officer. The Court noted that the identity of demand was not enough for immediate merits review and held that rectification under Section 161 remained the appropriate first remedy, as the six-month period had not expired. The petitioner was allowed to seek rectification within two weeks, to be decided after hearing, with liberty to pursue any available appellate remedy thereafter. The Court left the merits of the overlap objection open.
Overlapping GST proceedings were not examined on merits in writ jurisdiction because the petitioner had not participated in the second proceedings to place the alleged overlap before the proper officer. The Court noted that the identity of demand was not enough for immediate merits review and held that rectification under Section 161 remained the appropriate first remedy, as the six-month period had not expired. The petitioner was allowed to seek rectification within two weeks, to be decided after hearing, with liberty to pursue any available appellate remedy thereafter. The Court left the merits of the overlap objection open.
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