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...
Input Tax Credit (ITC) claim - Non-payment to suppliers exceeding 180 days - Despite the petitioner's response and submission of supporting documents, including a Chartered Accountant's certificate, the assessing authority based its decision on the total trade payables of the petitioner without considering the specific payables related to Tamil Nadu. The court noted that companies are not required to file state-specific financial statements under the Companies Act, 2013. The petitioner agreed to provide invoices related to the sum attributable to Tamil Nadu. - Matter restored back for re-adjudication - HC
Input Tax Credit (ITC) claim - Non-payment to suppliers exceeding 180 days - Despite the petitioner's response and submission of supporting documents, including a Chartered Accountant's certificate, the assessing authority based its decision on the total trade payables of the petitioner without considering the specific payables related to Tamil Nadu. The court noted that companies are not required to file state-specific financial statements under the Companies Act, 2013. The petitioner agreed to provide invoices related to the sum attributable to Tamil Nadu. - Matter restored back for re-adjudication - HC
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