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...
Profiteering established by increasing base prices of movie tickets despite GST rate reduction from 28% to 18% for admission tickets above Rs. 100, contravening Section 171 of CGST Act. Respondent failed to pass on benefit of Rs. 88,67,790/- to customers from 01.01.2019 to 30.04.2020. Directed to reduce ticket prices commensurately and deposit profiteered amount with interest at 18% in equal parts in Central and State Consumer Welfare Funds within 3 months, failing which to be recovered as per GST Act. Penalty imposed for denying rate reduction benefit from 01.01.2020 onwards, constituting offence u/s 171(3A) of CGST Act.
Profiteering established by increasing base prices of movie tickets despite GST rate reduction from 28% to 18% for admission tickets above Rs. 100, contravening Section 171 of CGST Act. Respondent failed to pass on benefit of Rs. 88,67,790/- to customers from 01.01.2019 to 30.04.2020. Directed to reduce ticket prices commensurately and deposit profiteered amount with interest at 18% in equal parts in Central and State Consumer Welfare Funds within 3 months, failing which to be recovered as per GST Act. Penalty imposed for denying rate reduction benefit from 01.01.2020 onwards, constituting offence u/s 171(3A) of CGST Act.
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