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...
Input tax credit eligibility on renting commercial property deemed inadmissible as the matter is sub judice before the Supreme Court. Applicability of reverse charge mechanism on inward freight held inadmissible due to the issue already decided in prior proceedings, invoking Section 98(2) proviso of CGST Act. Query regarding setting off input and output tax for multiple businesses under same GST number held outside Section 97(2) purview, hence cannot be answered by the Authority.
Input tax credit eligibility on renting commercial property deemed inadmissible as the matter is sub judice before the Supreme Court. Applicability of reverse charge mechanism on inward freight held inadmissible due to the issue already decided in prior proceedings, invoking Section 98(2) proviso of CGST Act. Query regarding setting off input and output tax for multiple businesses under same GST number held outside Section 97(2) purview, hence cannot be answered by the Authority.
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