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...
Liability on the head of IGST and interest with a penalty - The major contention arises from the treatment of sundry creditors' liability. The petitioner asserts that the liability was wrongly assessed without considering the tax component and argues for the deduction of the Input Tax Credit (ITC) tax element from the total sundry credit amount. - The learned Additional Government Pleader suggests that the petitioner has the option to file an application u/s161 of the GST Act within 90 days to rectify any errors in the assessment order. - The High court disposed of the writ petition with the liberty granted to the petitioner to file an application u/s 161 of the GST Act, along with necessary documents.
Liability on the head of IGST and interest with a penalty - The major contention arises from the treatment of sundry creditors' liability. The petitioner asserts that the liability was wrongly assessed without considering the tax component and argues for the deduction of the Input Tax Credit (ITC) tax element from the total sundry credit amount. - The learned Additional Government Pleader suggests that the petitioner has the option to file an application u/s161 of the GST Act within 90 days to rectify any errors in the assessment order. - The High court disposed of the writ petition with the liberty granted to the petitioner to file an application u/s 161 of the GST Act, along with necessary documents.
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