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...
Denial of Input Tax Credit (ITC) erroneously - The supplier made a mistake by filing the return in Form GSTR-1 by specifying total integrated tax (IGST) as zero in the relevant column - The High Court observed that while suppliers may make errors, recipients are equally responsible for rectifying incorrect claims to maintain GST system integrity. However, it noted that in this case, the SGST component did reach the State of Tamil Nadu, contradicting the assessing officer's view. - The Court quashed the impugned order. The matter was remanded to the assessing officer for reconsideration, with directions to issue a fresh assessment order within a specified timeframe.
Denial of Input Tax Credit (ITC) erroneously - The supplier made a mistake by filing the return in Form GSTR-1 by specifying total integrated tax (IGST) as zero in the relevant column - The High Court observed that while suppliers may make errors, recipients are equally responsible for rectifying incorrect claims to maintain GST system integrity. However, it noted that in this case, the SGST component did reach the State of Tamil Nadu, contradicting the assessing officer's view. - The Court quashed the impugned order. The matter was remanded to the assessing officer for reconsideration, with directions to issue a fresh assessment order within a specified timeframe.
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