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...
Rule 86A permits blocking of input tax credit only when there is adequate material supporting reasons to believe that credit was fraudulently availed or otherwise ineligible, and a revocation representation must be decided by a reasoned speaking order. On the facts discussed, the blockage was sustained because the order recorded that the suppliers lacked physical infrastructure, CCTV verification did not show vehicle movement, and inward slips suggested manipulation of records. The restriction was confined to credit linked to the questioned transactions and was found not disproportionate, though the Revenue was expected to pursue the consequential show-cause and adjudication without delay.
Rule 86A permits blocking of input tax credit only when there is adequate material supporting reasons to believe that credit was fraudulently availed or otherwise ineligible, and a revocation representation must be decided by a reasoned speaking order. On the facts discussed, the blockage was sustained because the order recorded that the suppliers lacked physical infrastructure, CCTV verification did not show vehicle movement, and inward slips suggested manipulation of records. The restriction was confined to credit linked to the questioned transactions and was found not disproportionate, though the Revenue was expected to pursue the consequential show-cause and adjudication without delay.
Note: It is a system-generated summary and is for quick reference only.