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...
Perishable goods detained in transit were ordered to be released to the petitioner because the demand order disclosed no concrete or prima facie material negating the petitioner's ownership of the consignment. The Court held that release had to follow compliance with the statutory payment required from the owner under Section 129(1)(a) of the GST law, and that the revenue could not withhold release merely on a disputed ownership basis. It also clarified that, if the petitioner did not pursue the statutory appeal and the demand attained finality, the revenue remained free to proceed in accordance with law.
Perishable goods detained in transit were ordered to be released to the petitioner because the demand order disclosed no concrete or prima facie material negating the petitioner's ownership of the consignment. The Court held that release had to follow compliance with the statutory payment required from the owner under Section 129(1)(a) of the GST law, and that the revenue could not withhold release merely on a disputed ownership basis. It also clarified that, if the petitioner did not pursue the statutory appeal and the demand attained finality, the revenue remained free to proceed in accordance with law.
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