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...
Issuing a composite show-cause notice covering multiple tax periods under the CGST/KGST regime was treated as a jurisdictional defect, following the view that clubbing separate periods in one notice is illegal and impermissible. The impugned notice and the adjudication order founded on it were set aside. Liberty was reserved to the revenue to initiate fresh proceedings through separate show-cause notices for each tax period, and all other contentions were left open.
Issuing a composite show-cause notice covering multiple tax periods under the CGST/KGST regime was treated as a jurisdictional defect, following the view that clubbing separate periods in one notice is illegal and impermissible. The impugned notice and the adjudication order founded on it were set aside. Liberty was reserved to the revenue to initiate fresh proceedings through separate show-cause notices for each tax period, and all other contentions were left open.
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