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 entertain the writ petition under Article 226 because the challenge to the search authorization, stock discrepancy assessment, and penalty order involved disputed factual matters better examined under the GST statutory framework. Applying the rule that an aggrieved person should ordinarily pursue the remedy created by statute, the Court held that an effective appellate remedy was available and interference in writ jurisdiction was unwarranted. The petitioner was left to file an appeal and was granted liberty to raise all legal and factual grounds, including a request for condonation of delay for the period spent in prosecuting the writ petition.
The High Court declined to entertain the writ petition under Article 226 because the challenge to the search authorization, stock discrepancy assessment, and penalty order involved disputed factual matters better examined under the GST statutory framework. Applying the rule that an aggrieved person should ordinarily pursue the remedy created by statute, the Court held that an effective appellate remedy was available and interference in writ jurisdiction was unwarranted. The petitioner was left to file an appeal and was granted liberty to raise all legal and factual grounds, including a request for condonation of delay for the period spent in prosecuting the writ petition.
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