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...
Seeking opening of portal for filing of Form TRAN-1 - Crystallization of input tax credit - vested right - Keeping the underlying principle in mind if the matter is examined then we are inclined to lean in favour of the writ petitioners and affirm the directions issued by the learned Single Judge - the substantial part of the order and the directions issued by the learned writ Court as well as reasoning given merits acceptance - The writ petitions are disposed of by granting liberty to the petitioners to file individual tax credit in GSTR-3b forms for the month of June, 2022 to be filed in the month of July, 2022 subject to verification of genuineness of the claim of the petitioner in all these cases. - HC
Seeking opening of portal for filing of Form TRAN-1 - Crystallization of input tax credit - vested right - Keeping the underlying principle in mind if the matter is examined then we are inclined to lean in favour of the writ petitioners and affirm the directions issued by the learned Single Judge - the substantial part of the order and the directions issued by the learned writ Court as well as reasoning given merits acceptance - The writ petitions are disposed of by granting liberty to the petitioners to file individual tax credit in GSTR-3b forms for the month of June, 2022 to be filed in the month of July, 2022 subject to verification of genuineness of the claim of the petitioner in all these cases. - HC
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