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...
Rectification of inadvertent error in filing of GSTR-1 - Denial of ITC to the buyer of goods for non-reflection of the invoices in FORM-GSTR-2A - The court granted liberty to the petitioner to file the Rectification Application either online or manually within four weeks. The decision on this application will determine the petitioner's subsequent claims against the department or Mahindra Logistics. The court left all legal contentions, including the challenge to the vires of the provisions, open for future consideration. - HC
Rectification of inadvertent error in filing of GSTR-1 - Denial of ITC to the buyer of goods for non-reflection of the invoices in FORM-GSTR-2A - The court granted liberty to the petitioner to file the Rectification Application either online or manually within four weeks. The decision on this application will determine the petitioner's subsequent claims against the department or Mahindra Logistics. The court left all legal contentions, including the challenge to the vires of the provisions, open for future consideration. - HC
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