TNMM comparability using audited accounts and working-capital adjustments can eliminate unwarranted transfer-pricing additions where verified margins ...
Gross-profit additions on disputed purchases require reasoned appellate determination; disclosed claims alone do not support inaccurate-particulars pe...
Limitation after transfer-pricing remand: fresh TPO reference did not extend the assessment deadline, rendering the consequential assessment time-barr...
Interim judicial restraint on tax deduction prevents default, while supporting reasonable cause and penalty deletion for foreign-leg LFC reimbursement...
Palmolein classification defeated the crude-oil concession; material misdeclaration sustained recovery and confiscation, while separate false-document...
Transitional Credit - Revision of return on MVAT for June 2017 - the order should be self-speaking. It cannot be that the Authority passes an order without reasons, and then arguments are advanced in a writ jurisdiction at the first instance. Furthermore, the Petitioner before us is not the one who is delaying the payment of taxes. Remand is also necessary to highlight the need to give a reasoned order. The learned Counsel for the parties jointly state that the exercise of power under section 25 of the MVAT Act of 2002 in respect of the order in question would be within the period of limitation. - Matter restored back - HC
Transitional Credit - Revision of return on MVAT for June 2017 - the order should be self-speaking. It cannot be that the Authority passes an order without reasons, and then arguments are advanced in a writ jurisdiction at the first instance. Furthermore, the Petitioner before us is not the one who is delaying the payment of taxes. Remand is also necessary to highlight the need to give a reasoned order. The learned Counsel for the parties jointly state that the exercise of power under section 25 of the MVAT Act of 2002 in respect of the order in question would be within the period of limitation. - Matter restored back - HC
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