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...
Refund claim of tax wrongly paid or allowing ITC to the correct party - inadvertent mistake in filling the GST number in the GSTR-1 - seeking permission to rectify the details of the recipient of the service in the form of GSTR-1 - Difficulty in following the Circular as the GST portal did not permit to rectify the defects - As the Circular of the year 2019 restricts only electronic filing and as the contention of the respondents that the claim of the petitioner is barred by limitation is not acceptable, the respondents cannot retain the amount, which was paid by the petitioner. - HC
Refund claim of tax wrongly paid or allowing ITC to the correct party - inadvertent mistake in filling the GST number in the GSTR-1 - seeking permission to rectify the details of the recipient of the service in the form of GSTR-1 - Difficulty in following the Circular as the GST portal did not permit to rectify the defects - As the Circular of the year 2019 restricts only electronic filing and as the contention of the respondents that the claim of the petitioner is barred by limitation is not acceptable, the respondents cannot retain the amount, which was paid by the petitioner. - HC
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