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...
Project-wise anti-profiteering analysis under GST upheld where the Tribunal accepted a case-specific methodology for comparing pre-GST and post-GST ITC, allocated the benefit across similarly situated homebuyers, and rejected objections on natural justice, scope of inquiry, and time limits. It found that additional input tax credit had arisen in the project, that the respondent had not passed on the full recipient-specific benefit, and that excess benefit given to some buyers could not offset shortfall owed to others. The balance amount was sustained with 18% compensatory interest, but penalty was declined because the penal provision was held inapplicable to the period in question.
Project-wise anti-profiteering analysis under GST upheld where the Tribunal accepted a case-specific methodology for comparing pre-GST and post-GST ITC, allocated the benefit across similarly situated homebuyers, and rejected objections on natural justice, scope of inquiry, and time limits. It found that additional input tax credit had arisen in the project, that the respondent had not passed on the full recipient-specific benefit, and that excess benefit given to some buyers could not offset shortfall owed to others. The balance amount was sustained with 18% compensatory interest, but penalty was declined because the penal provision was held inapplicable to the period in question.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4798
Join Channel
TaxTMI 
