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 16(5) of the Central Goods and Services Tax Act overrides section 16(4) and preserves input tax credit entitlement for specified financial years where the return under section 39 was filed by 30 November 2021. For Financial Year 2018-19, a return filed on 23 October 2019 fell within the preserved period. Denial of the related input tax credit was therefore impermissible, and the Order-in-Original denying the claim was set aside and quashed.
Section 16(5) of the Central Goods and Services Tax Act overrides section 16(4) and preserves input tax credit entitlement for specified financial years where the return under section 39 was filed by 30 November 2021. For Financial Year 2018-19, a return filed on 23 October 2019 fell within the preserved period. Denial of the related input tax credit was therefore impermissible, and the Order-in-Original denying the claim was set aside and quashed.
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