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...
Retrospective insertion of Section 16(5) of the CGST Act saved input tax credit claims for the specified financial years when returns were filed up to 30.11.2021, notwithstanding the limitation in Section 16(4). The High Court followed its earlier common order and quashed the impugned reversal to the extent it denied ITC solely on limitation, making that coercive action unsustainable on that ground alone. The Department's liberty was preserved to proceed in accordance with law on separate issues such as discrepancy, wrong availment, excess claim, or fake ITC, if any.
Retrospective insertion of Section 16(5) of the CGST Act saved input tax credit claims for the specified financial years when returns were filed up to 30.11.2021, notwithstanding the limitation in Section 16(4). The High Court followed its earlier common order and quashed the impugned reversal to the extent it denied ITC solely on limitation, making that coercive action unsustainable on that ground alone. The Department's liberty was preserved to proceed in accordance with law on separate issues such as discrepancy, wrong availment, excess claim, or fake ITC, if any.
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