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...
The High Court addressed the demand for interest u/s 50 of the Central Goods and Services Tax Act, 2017. It clarified that interest on delayed tax payment is not applicable from the date of deposit in the electronic cash ledger until the filing of the return. The Court emphasized that interest is compensatory and can only be imposed from the due date of tax payment until the actual deposit in the electronic cash ledger. Referring to relevant legal precedents, the Court highlighted that once the amount is credited to the government account, the tax liability is discharged, and no interest is payable if a sufficient balance remains in the electronic cash ledger. The Court concluded that the petitioner cannot be held liable for interest from the deposit date to the return filing date. The petition was allowed in favor of the petitioner.
The High Court addressed the demand for interest u/s 50 of the Central Goods and Services Tax Act, 2017. It clarified that interest on delayed tax payment is not applicable from the date of deposit in the electronic cash ledger until the filing of the return. The Court emphasized that interest is compensatory and can only be imposed from the due date of tax payment until the actual deposit in the electronic cash ledger. Referring to relevant legal precedents, the Court highlighted that once the amount is credited to the government account, the tax liability is discharged, and no interest is payable if a sufficient balance remains in the electronic cash ledger. The Court concluded that the petitioner cannot be held liable for interest from the deposit date to the return filing date. The petition was allowed in favor of the petitioner.
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