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...
Reversal of ineligible ITC - The case involved a trader served with a notice to pay/reverse ineligible Input Tax Credit (ITC) due to a discrepancy between GSTR-2A and GSTR-3B filings. The trader argued that they acted in good faith based on invoices from a selling dealer whose GST registration was subsequently cancelled. Legal precedents were cited to challenge the legality of the notice. The High Court determined that the notice was an intimation under Section 74(5), allowing the trader to address the issue before formal proceedings. The Court directed the trader to take necessary actions or file objections, with the adjudicating officer examining objections and relevant documents before initiating formal proceedings.
Reversal of ineligible ITC - The case involved a trader served with a notice to pay/reverse ineligible Input Tax Credit (ITC) due to a discrepancy between GSTR-2A and GSTR-3B filings. The trader argued that they acted in good faith based on invoices from a selling dealer whose GST registration was subsequently cancelled. Legal precedents were cited to challenge the legality of the notice. The High Court determined that the notice was an intimation under Section 74(5), allowing the trader to address the issue before formal proceedings. The Court directed the trader to take necessary actions or file objections, with the adjudicating officer examining objections and relevant documents before initiating formal proceedings.
Note: It is a system-generated summary and is for quick reference only.
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