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 errors in filing GST Returns - The case involved errors made by the petitioner in their GST returns for the period July 2017, initially by incorrectly reflecting the SGST tax component and subsequently by reversing ITC under IGST instead of SGST. The petitioner promptly notified the authorities about these errors and submitted a detailed reply to the show cause notice. The court, considering similar precedents and the challenges faced by taxpayers during the early stages of GST implementation, directed the authorities to permit the petitioner to rectify their GST returns, emphasizing the need for a flexible approach to address inadvertent errors.
Rectification of errors in filing GST Returns - The case involved errors made by the petitioner in their GST returns for the period July 2017, initially by incorrectly reflecting the SGST tax component and subsequently by reversing ITC under IGST instead of SGST. The petitioner promptly notified the authorities about these errors and submitted a detailed reply to the show cause notice. The court, considering similar precedents and the challenges faced by taxpayers during the early stages of GST implementation, directed the authorities to permit the petitioner to rectify their GST returns, emphasizing the need for a flexible approach to address inadvertent errors.
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