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...
Imposition of GST on trade payables - challenge on the ground that the impugned order travelled beyond the scope of the show cause notice and the entire trade payables of the petitioner were subject to GST - The court found the imposition of GST on the petitioner's total trade payables prima facie untenable, considering the petitioner's compliance with statutory requirements for availing ITC. The court agreed that there was a case for more detailed reconsideration regarding GST imposition on inward supplies and availed ITC. It ordered the petitioner to remit 10% of the disputed tax demand under all heads, except trade payables, for reconsideration.
Imposition of GST on trade payables - challenge on the ground that the impugned order travelled beyond the scope of the show cause notice and the entire trade payables of the petitioner were subject to GST - The court found the imposition of GST on the petitioner's total trade payables prima facie untenable, considering the petitioner's compliance with statutory requirements for availing ITC. The court agreed that there was a case for more detailed reconsideration regarding GST imposition on inward supplies and availed ITC. It ordered the petitioner to remit 10% of the disputed tax demand under all heads, except trade payables, for reconsideration.
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