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...
Validity of demand of GST and denial of input tax credit (ITC) - The High Court held that, u/s 16 of the TNGST Act read with Rule 36 of the rules framed thereunder, the registered person is under an obligation to establish purchase, including receipt of goods or services, as the case may be - Ordinarily, the petitioner would be required to produce invoices, e-way bills, payment receipts, lorry receipts, delivery challans and the like to establish purchase and receipt of goods. Since the impugned order was issued primarily on the basis that such documents were not submitted by the petitioner, it is not appropriate to adjudicate this issue in exercise of discretionary jurisdiction when the petitioner has an alternative remedy.
Validity of demand of GST and denial of input tax credit (ITC) - The High Court held that, u/s 16 of the TNGST Act read with Rule 36 of the rules framed thereunder, the registered person is under an obligation to establish purchase, including receipt of goods or services, as the case may be - Ordinarily, the petitioner would be required to produce invoices, e-way bills, payment receipts, lorry receipts, delivery challans and the like to establish purchase and receipt of goods. Since the impugned order was issued primarily on the basis that such documents were not submitted by the petitioner, it is not appropriate to adjudicate this issue in exercise of discretionary jurisdiction when the petitioner has an alternative remedy.
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