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 excess input tax credit availed - bonafide mistake - The petitioner argued that the incorrect claiming of IGST instead of CGST was a bonafide mistake and should not lead to the disallowance of the input tax credit. However, the Court held that since the petitioner failed to move any application within the prescribed time limit for correcting the mistake or claiming the refund of the IGST, it could not intervene to amend the statutory provisions.
Reversal of excess input tax credit availed - bonafide mistake - The petitioner argued that the incorrect claiming of IGST instead of CGST was a bonafide mistake and should not lead to the disallowance of the input tax credit. However, the Court held that since the petitioner failed to move any application within the prescribed time limit for correcting the mistake or claiming the refund of the IGST, it could not intervene to amend the statutory provisions.
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