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...
Discrepancies between input tax credit availed by petitioner in GSTR 3B and auto-populated GSTR 2A. Court granted partial relief by setting aside impugned order confirming IGST demand and interest, subject to petitioner depositing Rs. 10,000. Petitioner to file reply to show cause notice with deposit within 30 days. Impugned order quashed, treated as addendum to show cause notice. Respondent to pass fresh order on merits expeditiously, preferably within two months after hearing petitioner. Petition allowed.
Discrepancies between input tax credit availed by petitioner in GSTR 3B and auto-populated GSTR 2A. Court granted partial relief by setting aside impugned order confirming IGST demand and interest, subject to petitioner depositing Rs. 10,000. Petitioner to file reply to show cause notice with deposit within 30 days. Impugned order quashed, treated as addendum to show cause notice. Respondent to pass fresh order on merits expeditiously, preferably within two months after hearing petitioner. Petition allowed.
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