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...
A HC declined to entertain a writ petition challenging GST detention and release proceedings because the tax and penalty were paid after service of notice in Form GST MOV-07 and the goods were then released, with no contemporaneous protest shown. The Court treated the proceedings as concluded upon payment, held that the penalty order was appealable, and noted that no appeal had been filed within the prescribed period. It found no demonstrated violation of natural justice or jurisdictional error to justify bypassing the statutory appellate remedy, and dismissed the petition as devoid of merit.
A HC declined to entertain a writ petition challenging GST detention and release proceedings because the tax and penalty were paid after service of notice in Form GST MOV-07 and the goods were then released, with no contemporaneous protest shown. The Court treated the proceedings as concluded upon payment, held that the penalty order was appealable, and noted that no appeal had been filed within the prescribed period. It found no demonstrated violation of natural justice or jurisdictional error to justify bypassing the statutory appellate remedy, and dismissed the petition as devoid of merit.
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