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...
Wrong availment and utilization of Input Tax Credit (ITC) - The petitioner, engaged in the business of dealing in copper waste and scrap, provided ledger accounts, tax invoices, and E-way bills as evidence of legitimate purchases, but the Assessing Officer did not consider these documents. The court found that the impugned orders lacked discussion on the petitioner's documents and did not address deficiencies or inadequacies in the evidence provided. Consequently, the matters were remanded for reconsideration, with the second respondent directed to reissue a fresh assessment order after giving the petitioner a reasonable opportunity. - HC
Wrong availment and utilization of Input Tax Credit (ITC) - The petitioner, engaged in the business of dealing in copper waste and scrap, provided ledger accounts, tax invoices, and E-way bills as evidence of legitimate purchases, but the Assessing Officer did not consider these documents. The court found that the impugned orders lacked discussion on the petitioner's documents and did not address deficiencies or inadequacies in the evidence provided. Consequently, the matters were remanded for reconsideration, with the second respondent directed to reissue a fresh assessment order after giving the petitioner a reasonable opportunity. - HC
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