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...
Ratification of resignation acceptance validates separation retrospectively, while withdrawal may be refused through reasoned administrative discretio...
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Availment of wrongful credit - bonafide mistake - The High Court observed that the mistake made by the appellants was inadvertent, and despite the acknowledgment of the error by the adjudicating authority, the demand was confirmed without providing any guidance or assistance to rectify the error. Considering previous legal precedents and the transitional phase of legislation, the court directed the authorities to enable the appellants to rectify the mistake and submit the correct form within a specified timeframe. Additionally, the Nodal Officer of IT Grievance Redressal Mechanism was directed to facilitate the filing process and provide options for manual rectification if necessary.
Availment of wrongful credit - bonafide mistake - The High Court observed that the mistake made by the appellants was inadvertent, and despite the acknowledgment of the error by the adjudicating authority, the demand was confirmed without providing any guidance or assistance to rectify the error. Considering previous legal precedents and the transitional phase of legislation, the court directed the authorities to enable the appellants to rectify the mistake and submit the correct form within a specified timeframe. Additionally, the Nodal Officer of IT Grievance Redressal Mechanism was directed to facilitate the filing process and provide options for manual rectification if necessary.
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