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 writ challenge to denial of input tax credit, the High Court held that the genuineness of supply required a fuller examination where the supplier was registered during the relevant period, the invoices reflected vehicle details, and the petitioner asserted that transport was arranged by the supplier and tax had been paid on the supplies. The order was unsustainable because the proposal was confirmed merely for want of lorry receipts and weighment slips, without considering that material evidence. The impugned order was set aside and the matter remanded for fresh consideration, with liberty to file additional documents and after affording a reasonable opportunity of hearing.
In a writ challenge to denial of input tax credit, the High Court held that the genuineness of supply required a fuller examination where the supplier was registered during the relevant period, the invoices reflected vehicle details, and the petitioner asserted that transport was arranged by the supplier and tax had been paid on the supplies. The order was unsustainable because the proposal was confirmed merely for want of lorry receipts and weighment slips, without considering that material evidence. The impugned order was set aside and the matter remanded for fresh consideration, with liberty to file additional documents and after affording a reasonable opportunity of hearing.
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