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...
Storage of stock in premises not yet registered as an additional place of business did not, on the seizure records, justify confiscation of the available goods, redemption fine, or tax demand on the seized stock itself. The Court noted that the stock had not been liquidated at inspection and remained available, while the premises was later brought into the registration. The only consequence for the delayed registration default was a general penalty under the GST enactments. Tax, interest and penalty could still be redetermined only for any goods already sold.
Storage of stock in premises not yet registered as an additional place of business did not, on the seizure records, justify confiscation of the available goods, redemption fine, or tax demand on the seized stock itself. The Court noted that the stock had not been liquidated at inspection and remained available, while the premises was later brought into the registration. The only consequence for the delayed registration default was a general penalty under the GST enactments. Tax, interest and penalty could still be redetermined only for any goods already sold.
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