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...
Transitional Credit (ITC) - Permission for re-opening the common portal so as to enable the petitioner to submit the Form GST TRAN-1 electronically or to permit the petitioner to manually submit Form GST-TRAN-1 - In the initial months of implementation of GST enactment, there was confusion as to which of the assessees would be assessed by the Commercial Tax Department and which of the assessee would be assessed by the officers under the Central Government from the Central Excise Department - there are no justification in the stand of the respondent in not allowing the credit to be utilised. - HC
Transitional Credit (ITC) - Permission for re-opening the common portal so as to enable the petitioner to submit the Form GST TRAN-1 electronically or to permit the petitioner to manually submit Form GST-TRAN-1 - In the initial months of implementation of GST enactment, there was confusion as to which of the assessees would be assessed by the Commercial Tax Department and which of the assessee would be assessed by the officers under the Central Government from the Central Excise Department - there are no justification in the stand of the respondent in not allowing the credit to be utilised. - HC
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