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...
Seeking activation of GSTIN and granting final certificate of registration to the Petitioners from 01.07.2017 - The case involved a dispute regarding the activation of the petitioner's GSTIN under the Goods and Services Tax (GST) regime. Technical glitches initially resulted in the linkage of the petitioner's GSTIN to the PAN of a partnership firm instead of the proprietor's PAN. As a consequence, the petitioner faced challenges in availing input tax credit for purchases made during the transition period. - The High Court found merit in the petitioner's argument, ruling that they were not responsible for the initial technical errors. The Court ordered the activation of the correct GSTIN with retroactive effect from July 1, 2017, allowing the petitioner to avail input tax credit for the relevant period.
Seeking activation of GSTIN and granting final certificate of registration to the Petitioners from 01.07.2017 - The case involved a dispute regarding the activation of the petitioner's GSTIN under the Goods and Services Tax (GST) regime. Technical glitches initially resulted in the linkage of the petitioner's GSTIN to the PAN of a partnership firm instead of the proprietor's PAN. As a consequence, the petitioner faced challenges in availing input tax credit for purchases made during the transition period. - The High Court found merit in the petitioner's argument, ruling that they were not responsible for the initial technical errors. The Court ordered the activation of the correct GSTIN with retroactive effect from July 1, 2017, allowing the petitioner to avail input tax credit for the relevant period.
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