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...
Cotton seed oil cake supplied as cattle feed was treated as falling within the exemption under Notification No. 02/2017, so GST was not leviable for the period in question. Following an earlier Coordinate Bench decision in an identical matter, and noting that its applicability was not disputed, the Court held that the demand raised for non-payment of GST could not survive. The amount appropriated through DRC-03 against the demand was therefore unsustainable, and the petitioner was entitled to refund. The impugned adjudication and appellate orders, together with the consequential DRC-07, were quashed and refund was directed.
Cotton seed oil cake supplied as cattle feed was treated as falling within the exemption under Notification No. 02/2017, so GST was not leviable for the period in question. Following an earlier Coordinate Bench decision in an identical matter, and noting that its applicability was not disputed, the Court held that the demand raised for non-payment of GST could not survive. The amount appropriated through DRC-03 against the demand was therefore unsustainable, and the petitioner was entitled to refund. The impugned adjudication and appellate orders, together with the consequential DRC-07, were quashed and refund was directed.
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