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...
In a GST short-payment dispute, the HC noted that once outward supply was correctly disclosed in GSTR-1, the corresponding tax still had to be paid in GSTR-3B for the relevant period, so mere invocation of the stricter provision did not by itself warrant interference. After considering the later amnesty framework and the GST Council material, the Court treated the matter as one arising from return-filing glitches and admitted-liability mismatch capable of examination under the lesser provision. The demand and penalty order was quashed and the matter remitted for fresh consideration.
In a GST short-payment dispute, the HC noted that once outward supply was correctly disclosed in GSTR-1, the corresponding tax still had to be paid in GSTR-3B for the relevant period, so mere invocation of the stricter provision did not by itself warrant interference. After considering the later amnesty framework and the GST Council material, the Court treated the matter as one arising from return-filing glitches and admitted-liability mismatch capable of examination under the lesser provision. The demand and penalty order was quashed and the matter remitted for fresh consideration.
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