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...
Levy of interest u/s 50(3) - Wrong availment of Input of Tax Credit and reversal thereof - The court noted that the issue of levying interest under Section 50(3) of the Act for the wrongful availment and reversal of Input Tax Credit had been settled, as evidenced by the circular and various judgments cited. Additionally, the court considered the retrospective amendment in Section 50(3) of the Finance Act, 2022. - Matter remanded back to the adjudicating authority for fresh consideration in accordance with the law.
Levy of interest u/s 50(3) - Wrong availment of Input of Tax Credit and reversal thereof - The court noted that the issue of levying interest under Section 50(3) of the Act for the wrongful availment and reversal of Input Tax Credit had been settled, as evidenced by the circular and various judgments cited. Additionally, the court considered the retrospective amendment in Section 50(3) of the Finance Act, 2022. - Matter remanded back to the adjudicating authority for fresh consideration in accordance with the law.
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