Proper-officer jurisdiction under UPGST penalty provisions upheld; participation on merits prevents bypassing the statutory appellate remedy through w...
Transitioned CENVAT credit may validly satisfy mandatory pre-deposit requirements for legacy service tax appeals through Electronic Credit Ledger debi...
Building-plan sanction charges require statutory authority; unauthorised fees and GST were quashed, while labour cess must follow prescribed collectio...
Pure-agent exclusion fails where hotel booking facilitators receive third-party services themselves, making entire customer consideration taxable as r...
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...
Goodwill write-off already added back in computing taxable income should not be added again in assessment; an ambiguous rectification that potentially disallows goodwill beyond withdrawal of consequential depreciation cannot prejudice the assessee. The further goodwill disallowance was deleted, while the depreciation disallowance was sustained on the assessee's concession. A claim for set-off of brought-forward business losses requires verification of its quantum and eligibility from earlier-year records where it has not been adjudicated. That claim was remitted to the AO for verification and lawful set-off after reasonable opportunity. The appeal was partly allowed for statistical purposes.
Goodwill write-off already added back in computing taxable income should not be added again in assessment; an ambiguous rectification that potentially disallows goodwill beyond withdrawal of consequential depreciation cannot prejudice the assessee. The further goodwill disallowance was deleted, while the depreciation disallowance was sustained on the assessee's concession. A claim for set-off of brought-forward business losses requires verification of its quantum and eligibility from earlier-year records where it has not been adjudicated. That claim was remitted to the AO for verification and lawful set-off after reasonable opportunity. The appeal was partly allowed for statistical purposes.
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