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...
Cancellation of a supplier's GST registration or closure of business does not, by itself, defeat a purchaser's input tax credit entitlement; the department must establish collusion between the supplier and purchaser. Alleged fraudulent input tax credit availment was not prima facie supported where there was no material showing foundational supplier violations, and subsequent supplier non-existence or registration cancellation was insufficient. Anticipatory bail was granted because the petitioners lacked criminal antecedents, had appeared before authorities, and undertook to cooperate and produce documents; custodial interrogation was not warranted merely because the allegations involved an economic offence. Release was subject to investigation-cooperation and appearance conditions.
Cancellation of a supplier's GST registration or closure of business does not, by itself, defeat a purchaser's input tax credit entitlement; the department must establish collusion between the supplier and purchaser. Alleged fraudulent input tax credit availment was not prima facie supported where there was no material showing foundational supplier violations, and subsequent supplier non-existence or registration cancellation was insufficient. Anticipatory bail was granted because the petitioners lacked criminal antecedents, had appeared before authorities, and undertook to cooperate and produce documents; custodial interrogation was not warranted merely because the allegations involved an economic offence. Release was subject to investigation-cooperation and appearance conditions.
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