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...
Demand regarding disparity between e-way bills and GSTR 3B returns for 2018-19 to 2020-21 assessment periods. Petitioner stated disparity due to non-taxable supplies in e-way bills portal. Supporting documents not annexed to reply. Respondent did not refer to ITC-04 returns. Petitioner could have provided comprehensive explanation. Order set aside on condition of remitting Rs. 3,50,00,000/- towards disputed tax demand within six weeks and permitted to submit reply with relevant documents. Petition disposed of.
Demand regarding disparity between e-way bills and GSTR 3B returns for 2018-19 to 2020-21 assessment periods. Petitioner stated disparity due to non-taxable supplies in e-way bills portal. Supporting documents not annexed to reply. Respondent did not refer to ITC-04 returns. Petitioner could have provided comprehensive explanation. Order set aside on condition of remitting Rs. 3,50,00,000/- towards disputed tax demand within six weeks and permitted to submit reply with relevant documents. Petition disposed of.
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