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...
The High Court declined to examine the merits of the challenge to the GST show cause notice and consequential order, and directed the petitioner to pursue the appellate remedy instead. It permitted filing before the appellate authority within two weeks with a delay condonation application and statutory pre-deposit, and left open the request for lifting the bank lien, to be considered by the appellate authority in accordance with law.
The High Court declined to examine the merits of the challenge to the GST show cause notice and consequential order, and directed the petitioner to pursue the appellate remedy instead. It permitted filing before the appellate authority within two weeks with a delay condonation application and statutory pre-deposit, and left open the request for lifting the bank lien, to be considered by the appellate authority in accordance with law.
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