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...
Absence of a Document Identification Number in GST assessment orders was treated as an inherent defect that invalidated the orders, following prior High Court rulings. The impugned orders were set aside and the matter was remanded to the Assessing Officer for fresh adjudication after giving the taxpayer an opportunity of hearing. On the delay objection, the Court noted the controversy over service through the GST portal and the practical difficulties in accessing portal-served orders, and held that a delayed writ could still be entertained where the orders disclosed a patent irregularity. Relief was granted subject to deposit of 20% of the disputed tax, with issues on merits left open.
Absence of a Document Identification Number in GST assessment orders was treated as an inherent defect that invalidated the orders, following prior High Court rulings. The impugned orders were set aside and the matter was remanded to the Assessing Officer for fresh adjudication after giving the taxpayer an opportunity of hearing. On the delay objection, the Court noted the controversy over service through the GST portal and the practical difficulties in accessing portal-served orders, and held that a delayed writ could still be entertained where the orders disclosed a patent irregularity. Relief was granted subject to deposit of 20% of the disputed tax, with issues on merits left open.
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