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...
Section 148 permits the Government, on the Council's recommendations and subject to conditions and safeguards, to notify classes of registered persons and special procedures for registration, returns, tax payment and administration. Notification No. 22/2024-Central Tax, prescribing a procedure to implement retrospective input tax credit entitlement under Section 16(5), therefore falls within that power. The validity of the stipulated six-month period for rectification, particularly whether it contains adequate safeguards despite no extension mechanism for extraordinary circumstances, remains under consideration. The writ petitions were kept pending on that limited issue.
Section 148 permits the Government, on the Council's recommendations and subject to conditions and safeguards, to notify classes of registered persons and special procedures for registration, returns, tax payment and administration. Notification No. 22/2024-Central Tax, prescribing a procedure to implement retrospective input tax credit entitlement under Section 16(5), therefore falls within that power. The validity of the stipulated six-month period for rectification, particularly whether it contains adequate safeguards despite no extension mechanism for extraordinary circumstances, remains under consideration. The writ petitions were kept pending on that limited issue.
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