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...
Demand of GST - Discrepancy between the GSTR-3B returns and the auto populated GSTR-2A returns - The court observed that the tax demand solely pertained to the disparity between the Input Tax Credit (ITC) claimed in the GSTR-3B return and that reflected in the auto-populated GSTR-2A returns. It noted that the transaction's genuineness was not in question. - Acknowledging the contention regarding non-adherence to applicable circulars, the court deemed it appropriate to provide the petitioner an opportunity to contest the tax demand. - The court quashed the impugned assessment order with the condition that the petitioner remits 10% of the disputed tax demand within two weeks.
Demand of GST - Discrepancy between the GSTR-3B returns and the auto populated GSTR-2A returns - The court observed that the tax demand solely pertained to the disparity between the Input Tax Credit (ITC) claimed in the GSTR-3B return and that reflected in the auto-populated GSTR-2A returns. It noted that the transaction's genuineness was not in question. - Acknowledging the contention regarding non-adherence to applicable circulars, the court deemed it appropriate to provide the petitioner an opportunity to contest the tax demand. - The court quashed the impugned assessment order with the condition that the petitioner remits 10% of the disputed tax demand within two weeks.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4809 
Join Channel 
