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...
GST amnesty waiver eligibility for interest and penalty depends on the disputed input tax credit being availed within the prescribed statutory period, rather than on the financial year in which the underlying debit notes were issued. Excess credit first claimed in the December 2020 return fell outside the scheme's temporal scope despite its connection with debit notes from 2018-19. Guidance or decisions concerning input tax credit mismatch reconciliation cannot extend an expressly limited statutory period. The waiver was unavailable, and the interest and penalty on the excess credit claim were sustained.
GST amnesty waiver eligibility for interest and penalty depends on the disputed input tax credit being availed within the prescribed statutory period, rather than on the financial year in which the underlying debit notes were issued. Excess credit first claimed in the December 2020 return fell outside the scheme's temporal scope despite its connection with debit notes from 2018-19. Guidance or decisions concerning input tax credit mismatch reconciliation cannot extend an expressly limited statutory period. The waiver was unavailable, and the interest and penalty on the excess credit claim were sustained.
Note: It is a system-generated summary and is for quick reference only.