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...
Respondent resorted to profiteering by not reducing selling price commensurately despite GST rate reduction from 28% to 18% on cinema tickets above Rs. 100, from 01.01.2019 to 05.02.2019, profiteering Rs. 13,99,061 including GST. Respondent directed to reduce prices keeping rate reduction in view, having revised ticket price from Rs. 150 to Rs. 138 from 06.02.2019 depicting commensurate benefit passing. Respondent denied rate reduction benefit to customers violating Section 171(1) of CGST Act, 2017, committing offence u/s 171(3A) inserted from 01.01.2020, hence penalty u/s 171(3A) cannot be imposed retrospectively for said period.
Respondent resorted to profiteering by not reducing selling price commensurately despite GST rate reduction from 28% to 18% on cinema tickets above Rs. 100, from 01.01.2019 to 05.02.2019, profiteering Rs. 13,99,061 including GST. Respondent directed to reduce prices keeping rate reduction in view, having revised ticket price from Rs. 150 to Rs. 138 from 06.02.2019 depicting commensurate benefit passing. Respondent denied rate reduction benefit to customers violating Section 171(1) of CGST Act, 2017, committing offence u/s 171(3A) inserted from 01.01.2020, hence penalty u/s 171(3A) cannot be imposed retrospectively for said period.
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