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...
Short payment of GST on unreconciled sales turnover - non-reversal of Input Tax Credit (ITC) - The assessing officer rejected the petitioner's explanation, citing lethargy in maintaining accounts. However, the High Court found that even if the petitioner was lax in rectifying the mistake promptly, it didn't justify the substantial tax liability imposed solely based on a reporting error. The Court noted that the statute didn't allow rectification until the annual return was filed, and therefore, the petitioner's actions were within legal bounds.
Short payment of GST on unreconciled sales turnover - non-reversal of Input Tax Credit (ITC) - The assessing officer rejected the petitioner's explanation, citing lethargy in maintaining accounts. However, the High Court found that even if the petitioner was lax in rectifying the mistake promptly, it didn't justify the substantial tax liability imposed solely based on a reporting error. The Court noted that the statute didn't allow rectification until the annual return was filed, and therefore, the petitioner's actions were within legal bounds.
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