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...
GST assessment was set aside and remitted because the taxpayer's defence raised factual questions that had not been examined: whether input tax credit was inadvertently claimed under the IGST column, whether it was voluntarily reversed, and whether that reversal affected the liability imposed. The Court required the authority to give the taxpayer an opportunity to file a detailed response with supporting documents and to adjudicate the matter afresh in light of that defence and the statutory provisions. The taxpayer was also left free to seek revocation of suspension of registration by separate representation.
GST assessment was set aside and remitted because the taxpayer's defence raised factual questions that had not been examined: whether input tax credit was inadvertently claimed under the IGST column, whether it was voluntarily reversed, and whether that reversal affected the liability imposed. The Court required the authority to give the taxpayer an opportunity to file a detailed response with supporting documents and to adjudicate the matter afresh in light of that defence and the statutory provisions. The taxpayer was also left free to seek revocation of suspension of registration by separate representation.
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